Document 71xj6k9y1J5wOEXEGGmNKG5BR

AR226-2522 AMMONIUM PERFLUOROOCTANOATE (C-8) GROUNDWATER INVESTIGATION STEERING TEAM REPORT AUGUST 2003 CONSENT ORDER No. GW- 2001-019 Final C-8 GIST Regort TABLE OP CONTENTS: Executive Summary Introduction .............................. 3 11 West Virginia .P.r.iv.a.t.e.W..a.te.r..S.u.p.p.ly..S.o.u;r.c.es........... 13 Ohio Private Water Supply Sources .......;.- 19 West Virginia Public Water Supply So.u.r.c.e.s........... 22 Ohio Public Water Supply Sources .......... 25 Ohio River Sampling ................. 28 Surface Water and Gro.u.n.d.w..a.te.r..M.o.n.it.o.r.in.g........... 30 Groundwater Modeling .......... 45 References ........................... 48 Appendixes ................................... A: Site maps and Groundwater-Top maps B: Groundwater Data C: Consent Order No. GW-2001.019 CONTACT: Division Groundwater Program of Water and Waste Management 414 Summers Street Charleston, West Virginia 25301 304-558-2108 _pag^-2 MEMBERS OP THE GROUNDWATER INVESTIGATION STEERING T6AM; Don Criss, Geologist, Groundwater Program, West Virginia DEP Garth Conner, Environmental Engineer, Enforcement Division, Region III, United States EPA George R. Dasher, Geologist, Groundwater Program, West Virginia DEP Andrew Hartten, Principal Project Leader. DuPont Engineering Jack C. Hwang, Hydrogeologist, Region III, United States EPA Bill Toomey, Program Manager, Source Water Protection, Bureau for Public Health, West Virginia Health and Human Resources Roger Reinhart, Environmental Engineer, Water Division, Region III, United States EPA Dee Ann Staats, Ph.D., Science Advisor, West Virginia DEP Dave Watkins, Program Manager, Regulatory Programs Section, West Virginia DEP NON-VOTING GIST TEAM MEMBERS: I Sarah Wallace, Environmental Engineer, Division of Drinking and Ground Waters, Southeast District Office, Ohio EPA I Steve Williams, Hydrogeologist, Division of Drinking and Ground Waters, Southeast District Office, Ohio EPA Division of Water and Waste Management Final C-8 GIST Repoirt _______ 3 _______page AMMONIUM PERFLUOROOCTANOATE (C-8) GROUNDWATER INVESTIGATION STEERING TEAM REPORT EXECUTIVE SUMMARY A multi-media Consent Order (GWR-2001-019) was entered into between the West Virginia Department of Environmental Protection (WVDEP), the West Virginia Department of Health and Human Resources-Bureau for Public Health (WVDHHRBPH) and DuPont on November 14th, 2001. The Consent Order identified a series of requirements to be performed by the Parties (WVDEP, WVDHHR-BPH, and DuPont) Jn order to determine whether there has been any impact on human health and the environment as a result of releases of ammonium perfluorooctanoate (C-8), CAS Number 3815.26-1, to the environment from DuPont operations at the Washington Works main plant and three associated landfills (Local, Dry Run, and Letart). C-8 is a material used by DuPont in its fluoroproducts manufacturing process at its Washington Works Facility's located in Washington, Wood County, West Virginia. C-8 has not been identified as a hazardous substance, hazardous waste, or otherwise specifically regulated under West Virginia or federal statute or regulation. In accordance with Attachment A of the Consent Order, three tasks were to be performed by DuPont and evaluated by the Groundwater Investigation Steering Team (GIST). The GIST used a phased approach towards meeting these requirements. TASK A: Task A required Dupont to conduct a distance-phased public water supply service survey along the Ohio River on both the West Virginia and Ohio sides of the river. Subsequent to the Task A requirement, a one-mile (and possibly a two- and three-mile) radial distance of the Washington Works Facility and the Local, Letart, and Dry Run Landfills. The phased approach to the water and groundwater well use survey and sampling was intended to allow the GIST to focus efforts along potential C-8 impact transport pathways and eventually cease activities in directions where impacts were not present or where there were low concentrations. Division of Water and Waste Management Final C-8 GIST Report WBST VIRGINIA PRIVATE WATER SUPPLY SOURCES: j?agg_4 Conclusions: Initial sampling within a one-mile radius of the Washington Works Facility and private each of the three landfills resulted in varying levels of C-8 being found in water sources. Private water sourcFeasciwlitityhainnda toilnee-Lotocatwl Loa-mndilfeillrabdaisuesdwoenreCs-8amcopnlecdenatrroautinodnsthe private water WdeatsehcitnegdtognreWatoerrkthsan 1.0 ug/l in the one-mile radius. No fubrtahseerd on the lower scoounrcceenstrsaatimonpslindgetbeecyteodndinththeetwono-em- itloe trwaod'imusileis rnaedciuessssaarmy pling area. drNinokipnrgivwataetewrastecrreseonuinrcgeslevinelWoef s1t5V0iruggin/l.iaTwheerehifgohuensdt tcooenxcceneetrdattihoen Cde-8tected was 10.4 ug/l. Recommendations: Continued quarterly sampling of selected private water sources around the is Facility and Local and Dry Run Landfills for one year at the WreacsohminmgetonndeWdobryksthe GIST. Annual sampling of the private water soofutrhcees Letart Landfill is also recommended. Subsequently, the frequency sampling should then be re-evaluated. OHIO PRIVATE WATER SUPPLY SOURCES: Conclusions: Initial sampling within a one-mile radius of the Washington Works Facility resulting in varying levels of C-8 being found in approximately 94% of the water sources sampled. Private water sources within a one- to two-mile radius from the Washington detected at the outer Works Facility were sampled based on the levels of C-8 limits of the one-mile radius. scNroeepnriinvgatelewvealteorf 1so50urpcge/sl. inTOhehiohigwheersetfcoounncdetnotreaxticoeneddettheectCed-8wdarsink2i3n.g6 wyagt/el r RecommendQtiws: W Caosnhtiinnguteodn qWuoarrtkesrlFyascailmityplfionrgoonfeseyleeacrteisd rwecaotemr msoeunrdceeds bayrotuhnedOthhieo EPA. Subsequently, the frequency of the sampling should then be re-evaluated, Division of Water and WasttTManagement Final C-8 GIST Report __Paoej> WEST VIRGINIA PUBLIC WATER SUPPLY SYSTEMS: Conclusions: Ten public water supply systems along the Ohio River at various points up and downstream from the Washington Works Facility and Letart Landfill were sampled for C-8. No public water supply production wells in West Virginia were found to exceed the drinking water screening level of 150 ug/L The highest concentration detected was 1.87 ug/l. The widespread distribution and low concentrations of C-8 indicate that the primary migration pathways to the public water supplies are air emissions from the Washington Works Facility and pumping-induced infiltration from the Ohio River, which receives C-8 from the National Pollutant Discharge Elimination System (NPD6S) outfalls at the Washington Works Facility and the Letart Landfill. Recommendations: Continued quarterly sampling at the Lubeck Public Service District (PSD), DuPont Washington Works Facility, and General Electric public water systems for two years is recommended by the GIST. Also, annual sampling of the Blennerhassett Island, reason County PSD, and the Racine Lock and Dam Public Water System for two years is advised. Subsequently, the frequency of the sampling should then be re-evaluated. OHIO PUBLIC WATER SUPPLY SYSTEMS; Conclusions: Six public water supply production wells along the Ohio River at various points up and downstream from the Washington Works Facility and the Letart Landfill were sampled for C-8. No public water supply production wells in Ohio were found to exceed the C-8 drinking water screening level of 150 ug/l. The highest concentration detected was 8.58 Mg/l. The widespread distribution and the low concentrations of C-8 indicate that the primary migration pathways to the public water supplies are air emissions from the Washington Works Facility and pumping-induced infiltration from the Ohio River, which receives C-8 from NPDES outfalls at the Washington Works Facility and Letart Landfill. Division of Water and Waste Management Final C-8 GIST Report ___ Recommendations: pa.9e6 Continued quarterly sampling of the Little Hocking Water Association Public Water System for two years is recommended by the GIST. Also, annual sampling of the Tuppers Plains-Chester Water District Public Water System for two years is advised. Subsequently, the frequency of the sampling should then be re-evaluated. TASK B: Task B required the development and implementation of a monitoring plan that would determine the extent and presence of C-8 in drinking water, groundwater, and surface water in and around the Washington Works Facility and the three landfills, and to provide a compilation of all available groundwater/surface water monitoring and hydrogeologic characterization data for each facility. OHIO RIVER SURFACE WATER SAMPLING: Conclusions: Twelve sampling locations in the Ohio River at points up to 28.6 mites upstream of the Washington Works Facility and downstream to the Letart Landfill were sampled for C-8. No samples collected from the Ohio River were found to exceed the C-8 drinking water screening level of 150 ug/l. The highest concentration detected was 1.04 ug/l. Recommendations: No additional river sampling is recommended. SURFACE WATER AND OROUNDWATER MONITORING: This task included monitoring of the surface water and groundwater at the Washington Works Facility and the three landfills for four consecutive monthly events, followed by quarterly sampling thereafter. DRY RUN LANDFILL: Conclusions: C-8 is believed to be migrating, via groundwater and surface water, from the C8-containing waste that has been disposed of within the landfill. Division of Water and Waste Management Final C-8 GiST Report _ _____gage7 Groundwater flow is toward the west and toward the Dry Run valley at this site. C-8 concentrations measured within the one-mile radius of the site show that some off-site migration of C-8 may have occurred. The Dry Run Landfill is located within eight miles of the Washington Works Facility. The transport of C-8 via air emissions from the plant could potentially be the source of the very low concentrations of C-8 detected within the one-mile radius sampling area. There are no known complete exposure pathways for human receptors that exceed the C-8 drinking water screening level of 150 ug/l. Recommendations: Surface water and groundwater monitoring should continue at this site. The groundwater sampling should continue to be quarterly, while the outfall sampling can be either monthly or quarterly, as required by the site's NPDE8 permit. The C-8 concentrations in wells DRMW-13A and DRMW-13A should be monitored, as these wells appear to be the most vulnerable (down-gradient portion of the C-8 plume). The C-8 concentrations at the Dry Run leachate discharge location should be monitored. LETART LANDFILL: Conclusions: C-8 is believed to be migrating via surface water transport from the C'8 containing waste that has been disposed of within the landfill. Groundwater flow in the A Zone, D-E Zones, C Zone, and F Zone at the Letart Landfill is towards the Ohio River, and is away from the private water supplies in this area. Groundwater flow in the P Zone (the deepest zone) is generally believed to be towards the Ohio River and away from the private water supplies in this area; however, there may be a groundwater flow divide on the upper and northwestern side of the landfill. The annual C-8 loading from groundwater to the Ohio River indicates a very low concentration in the river from the landfill, and this is supported by the very low concentrations of C-8 in the Ohio River downstream of the landfill. It is possible, however, that this loading is contributing to the presence of low C-8 concentrations in some of the down river community water systems. Air emissions are not a viable migration pathway from the landfill because there Division of Water and Waste Management Final C-8 GIST Report _ _ pageg are no air emissions at the Letart Landfill. There are three complete exposure pathways for human receptors that exceed the CATT-established C-8 drinking water screening level of 150 ug/l. These are: contact with either surface water runoff (at the Cap Runoff location), leachate discharged to surface water at the toe of the Letart Landfill, and the resulting wet-weather stream that discharges into the Ohio River. However, these exposure routes are limited because of the remote location of the landfill, the very steep terrain, and the wet-weather nature of the stream. In addition, the fencing around the site limits trespasser access to the area, and the use of health and safety plans, standing operating procedures, and personal protective equipment also limits C-8 exposure for the on-site workers. . Recommendations: Surface water and groundwater monitoring should continue at this sit. The groundwater sampling should continue to be quarterly, while the outfall sampling can be either monthly or quarterly, as required by the site's NPDES permit. All three of the Zone A groundwater monitoring wells (LMW'1, LMW-7, and LMW-8) should be monitored for C-8 concentrations and groundwater flow direction. Zone F groundwater wells LMW-2A and LMW-12 should be monitored for C-8 concentrations and groundwater flow direction. LOCAL LANDFILL: Conclusions: C-8 is believed to be migrating via surface water transport from the C-8 containing waste that has been disposed of within the landfill. Groundwater flow from the Local Landfill is toward the northwest at this site and toward the Ohio River valley. Flow is also towards the Washington Works Facility. C-8 detected within the one- and two-mile radius sampling areas near the Washington Works Facility and Local Landfill is likely to have been transported from the plant via air emissions. There are no known complete exposure pathways for human receptors that exceed the C-8 Assessment of Toxicity Team (CATT)-established C-8 drinking water screening level of 150 ug/l. Recommendations: Division of Water and Waste Management Final C-8 GIST Report page 9 Surface water and groundwater monitoring should continue at this site. The groundwater sampling should continue to be semi-annually, while the outfall sampling can be either monthly or quarterly, as required by the site's NPDES permit. Three locations at the Local Landfill should be monitored: Outlet 101, Outlet LM1, and well LLMW-4. WASHINGTON WORKS FACILITY: Conclusions: The on-site Solid Waste Management Units (SWMUs) are believed to be the primary source of C-8 migration into the groundwater. Air deposition of C-8 onto the ground surface and its subsequent migration into the groundwater may also have occurred. No off-site migration of the groundwater is occurring, as long as DuPont's Western Well Field continues pumping. Some limited groundwater may migrate off-site in the northwest corner of the DuPont facility in response to the GE plant pumping their wells #3 and #4. Air emissions are believed to be the primary migration pathway of C-8 from the Washington Works Facility to adjacent areas in Ohio. Air emissions of C-8 from the Washington Works Facility are believed to be the source of C-8 detected in areas of West Virginia located adjacent to the facility and the Local Landfill. Air emissions of C-8 and the discharge of C-8 through the outfalls are believed to be the migration pathways of C-8 from the facility to the Ohio River, and-- most likely--from the river to the public water supplies located downstream. Air emissions of C-8 from the plant are believed to be the source for C-8 along the Ohio River upstream of the plant. There are no known complete exposure pathways for human receptors that exceed the CATT-established C-8 drinking water screening level of 150 ug/( at the Washington Works Facility. Recommendations: Surface water and groundwater monitoring should continue at this site. The groundwater sampling should continue to be quarterly, while the outfall sampling can be either monthly or quarterly, as required by the site's NPDES permit. Division of Water and Waste Management Final C-8 GIST Report - page 10 __ The following groundwater monitoring weds and outfalls require further monitoring at the Washington Works Facility: R04-MW02, P04-MW-2, Q04MW02. V05-PW01, N04-MW-01, and Outfall 005. It is important that DuPont further investigates the high concentrations of C-8 in these wells, which are located at the Washington Works Facility adjacent to the Ohio River. DuPont has stated (in their February 2003 Summary Report) that C-8 is confined to a perched aquifer and that the deeper aquifer contains no C-8. TASKC: Task C required the determination of the vertical and horizontal extent of any and all C-8 impacted groundwater exceeding 1 pg/l. This task also included an assessment of C-8 impacted surface water and/or groundwater at the Letart Landfill and its impact on the Ohio River and nearby public water systems along the river. GROUNDWAT6R MODELING; Groundwater modeling of the Washington Works Facility and surrounding area was conducted to evaluate the groundwater flow pathways and determine the potential of C-8 migration to off-site receptors. Conclusions: The Ohio River creates a groundwater divide in the Pleistocene alluvium under the river. As a result of production-well pumping at the Dupont Washington Works Facility and the neighboring GE facility, the C-8-impacted groundwater from the Washington Works Facility is not being drawn into either the Lubeck PSD municipal well field in West Virginia or the Little Hocking Water Association well field in Ohio. Some limited groundwater may migrate off-site in the northwest corner of the DuPont facility in response to GE pumping wells #3 and 4. Sources of C-8, for the Lubeck PSD and the Little Hocking Water Association, are coming from the Ohio River and dispersion by air. Recommendation: The URS Diamond model should be accepted as representing real-world conditions in determining groundwater flow and contaminant transport. Division of Water and Waste Management Final C.8 GIST Report j3age11 INTRODUCTION C-8 has been used by DuPont since the early 1950's in its fluoropolymer fluoropolymer related Residues containing C-8 from the Facility are or have been released manufacturing processes. manufacturing processes at the Washington Works disposed of at the facility, and otherwise tsohtiphpeeadir.ofdf-isscitheafrogreddetsotrtuhcetioOnhiaonRd/iover rd, isposal. DuPont also captures for recycling a portion of used C-8. No permits issued to Dupont authorizing release of pollutants to the environment Since as early the amount of C-8 that may be released. sampling to detect the caosn1ta9i9n0s, pDeucPifoicnltimhaitsatpioenrsfoormn ed regular, volfuanctialirtyiews ainteWr est Virginia, and has reported presence and level of C-8 in and around its samplings to WVDEP. As a result of DuPont's sampling, C-8 has the results of these in private and public water supplies. DuPont, detected in varying concentrations in the fluoropolymer manufacturing process, was been by and through its use of C-8 considered the likely source. Environmental Protection Agency (EPA), WVDEP. and WVDHHR- BPH The federal determined that it was desirable to ascertain the source of C-8 in drinking water of these for exposed to groundwater or surface waters in the area requested that DuPont submit all pfaecrisliotiness. pTotheentEiaPlAly. WVDEP, and WVDthHeHdRe-tBecPtHion and presence of C-8 in and around information and documents relating to that it would be of great importance to have tshueffsieciefanctilditaietas. upTohne wahgiecnhciteosdceotenrcmluindeedthe potential exposure risk of the presence of C-8 in the environment. Therefore, a C>8 Groundwater Investigation Steering Team (GIST) was activities that would be established in the Consent Order to oversee investigations and in drinking water, groundwater, to assess the presence and extent of plant, C-8 and the Local, Dry Run, and Letart conducted and surface water at and around the main Landfills. The GIST was made up of a team of scientists assembled from the WVDEP, of WVDHHR-BPH, EPA Region III, and DuPont In May 2002 a Memorandum WVDHHR-PBH. and DuPont with the Understanding (MOU) was signed by WVDEP, guidelines for Ohio EPA's participation in the GIST Ohio EPA. The MOU established in Ohio public drinking water supplies. due to the discovery of C-8 DuPont, througghroaunnadgwraeteedr-uupseonanthdirwd epllarstuyrvaenyd iudnendteifricthaetiosnupaenrdvissaiomnpolifntgheof cisterns) within the one- GgrIoSuTn, dcwoantdeurcwteedllsthaend other water sources (ie., springs and Identification and mile radius of the Washington Works Facility and the three landfills. permission. Based upon sampling of private wells was contingent upon landowner the GIST through the Consent Order was ceomnpcoewnterraetidontos poof sCs-i8blfyoeuxnpdainndwtahteerrasdoiualrcseusr,vey distance to include wells within a two- Division of Water and Waste Management 12 Final C-8 GIST Report or three-mile radius of the Washington Works Facility and the three landfills. Historical data and hydrogeologic information was evaluated in order to prioritize tinhveeisntiitgiaaltisocnopacetiovfitwieosrk(ef.ogr. cmoonntiintouriinngg gwreolul nindswtaaltleartiomnosn)itroerqinugireadndunadneyr aTdadsitkioCnaPl lume Identification. Upon conclusion of the Tasks wseitthfofirntdhiningsthaenCdocnosnecnlut sOiordnesrr, etghaerdGinISgT was GIST report cghroaurgneddwwatiethr qpureapliatyr,inagnda tfhinealerxetepnotrtof groundwater irmepgaacrdtsi.nTghtheefinneael d to conduct provides conclusions and makes recommendations protection of groundwater quality faunrdthherumwoarnk,hoeralttoh.taTkeheacfotilolonwsinngecreespsoartrysutomamsasruizrees those findings, conclusions, and recommendations of the GIST in fulfillment of the Consent Order. Division of Water and Waste Management Final C-8 OIST Report page^S _ WEST VIRGINIA PRIVATE WATER SUPPLY SOURCES Pursuant to Attachment A of the Consent Order, the Groundwater Use and Well Survey involved evaluating C-8 in groundwater initially within a one-mile radius from the Washington Works Facility and the three landfills (Local, Letart, and Dry Run) by sampling water from wells, cisterns, and springs. The area was expanded to a two-mile radius at the Washington Works Facility and the Local Landfill based on the initial results obtained from the one-mile radius survey and sampling. Between March 2002 and October 2002, DuPont's third-party contractor. Potesta Associates, Inc., performed a door-to-door well survey and collected samples following protocols established by the multi-media consent order. Representatives from the WVDEP and the Wood County Health Department accompanied Potesta Associates, Inc. personnel during the initial door-to-door survey. WASHINGTON WORKS FACILITY AND LOCAL LANDFILL: In April 2002, DuPont submitted a report to the GIST documenting the well survey and C-8 sample results within a one-mile radial distance around the DuPont Washington Works Facility and the Local Landfill. Because of the proximity of the Local Landfill to the DuPont Washington Works Facility, groundwater wells located within the combined one-mite radius (of both sites) in West Virginia were sampled. A total of 44 samples were collected from drinking water wells, non-drinking water wells, unused wells, springs, and cisterns. The C-8 concentration from drinking water wells ranged from 0.328 ug/l to 2.8 ug/l. The highest concentration of C-8 from the category of non-drinking water wells and unused wells was 14.3 ug/L C-8 was detected in all wells, springs, and cisterns sampled within the one-mile radius. A total of two samples collected in the one-mile radius had concentrations of C-8 abovelO ug/1. Because of the levels found in the onemile radius of the Washington Works Facility and the Local Landfill, the private water supply sources survey was extended by the GIST to a two-mile radius. In addition, private and industrial water supplies used for drinking water were sampled on a monthly basis until the CATT drinking water screening concentration of 150 ug/l was developed. The private water supply sources survey and C--8 sampling results within the one- to two-mile radius of the DuPont Washington Works Facility and the local landfill were submitted on August 2002 to the GIST. A total of 65 samples were collected and analyzed for C-8 including drinking water wells. The C-8 concentrations measured in drinking water wells ranged from non-detect (<0.010 ug/() to 0.889 ug/l. The highest concentration of C-8 from non-drinking water wells or unused wells was 1.57 ug/l. A spring sample, used for drinking water, had a concentration of 1.8 ug/I. Due to measured concentrations of C-8 in the two-mile radius indicating a decreasing trend in distance from the Washington Works Facility, the GIST determined that additional samples beyond the two-mile radius were not necessary. Division of Water and Waste Management Final C-8 GIST Report _ _ _ ._. _ P_age 14 In summary, C-8 was detected in 100% and 79% of the private water supply sources sampled in the one- and two-mile areas respectively. The concentrations of C-8 were lower in the two-mile radius area as compared to the one-mile radius. No private water supply sources in the one- or two-mile radius area exceeded the CATT-established C-8 drinking water screening level of 150 ug/l, The widespread distribution of C-8 in private water supply sources, combined with the lack of groundwater flow to this area from the Washington Works Facility and the Local landfill facilities, indicates that air emissions may be the primary migration pathway of C-8 from the facility to adjacent areas in West Virginia. RECOMMENOATIONS: Under the Consent Order, a significant number of private water supply samples have been collected that document the extent and current concentrations of C-8 in groundwater within the one- and two-mile radial areas. Most locations have been sampled at least once. It is unknown whether the concentrations detected in groundwater are the result of historic air deposition or result of air deposition in the last couple of years. Therefore, the GIST recommends that DuPont collect additional samples from the following selective locations to evaluate the current trend of C-8 concentrations in private water sources. Additional samples should be collected from the following sample locations, with the owner's permission: Drinking water wells with detected levels of C-8, Drinking water springs with detected levels of C-8, Non-drinking water wells with detected levels of C-8, Springs and cisterns with detected levels of C-8, and Wells or springs used for cattle above 5 ug/l (total 1). The GIST recommends selecting ten of these locations, with at least one or more from each category, for quarterly sampling for one year. Subsequently, the frequency of the sampling should then be re-evaluated. LETART LANDFILL: In April 2002. DuPont submitted a report to the GIST documenting the well survey and C-8 sampling results within the one-mile radial area around Letart Landfill. A total of 30 samples were collected from drinking water wells, non-drinking water wells, unused wells, springs, and cisterns. The C-8 concentration from drinking water wells ranged from non-detect (<0.01 ug/l) to 0.139 ug/l. The highest concentration of C-8 from the category of non-drinking water wells was 0.636 ug/l, from Brinker Run, which was named for sampling purposes" Route 33 Unnamed Stream." This concentration may be the result of surface water infiltration from the Letart Landfill into Brinker Run. Due to the low C-8 concentrations found at the Letart Landfill, and in the private water supply sources the survey was not extended by the GIST to a two-mile radial area. , Ijl^ Division of Water and Waste Management Final C-8 GIST Report page 15 . In summary, C-8 was detected in 6% of the private water supply sources sampled in the one-mile radial area. No private water supply sources samples exceeded the CATT-established C-8 drinking water screening level of 150 ug/l. RECOMMENDATIONS: Under the Consent Order, a significant number of private water supply samples were collected that document the extent and current concentrations of C-8 in private water supplies within a one-mile radius of the Letart Landfill. Each location was sampled at least once. The C-8 concentrations measured in all Letart Landfill one-mile radius samples were non detect or not quantifiable, except for one sample collected from a well used for drinking water that had a concentration of 0.139 pg/l and one sample collected from an unused well that had a concentration of 0.639 ug/l. The GIST required that the drinking water well with the C-8 concentration of 0.139 ug/l be resampled. The resident refused to have the well resampled. Each location has thus been sampled a single time, and there (s no clear trend as to whether the concentrations of C-8 detected in groundwater are increasing or decreasing. Therefore, the GIST is recommending that DuPont collect yearly samples from the GERLACHIBA and the BRINKERA private water supply sources, contingent upon permission of the well-owners, to evaluate the trend of C-8 concentrations in the private drinking water supplies. This sampling frequency should then be re-evaluated. DRY RUN LANDFILL: In April 2002, DuPont submitted a report to the GIST documenting the well survey and C-8 sampling results within the one-mile radius area around Dry Run Landfill. A total of 53 samples were collected from drinking water wells, non-drinking water wells, unused wells, springs, and cisterns. The C-8 concentrations from drinking water wells ranged from non-detect (<0.01 ug/l) to 0.422 ug/l. The highest concentration of C-8 from the category of non-drinking water wells and unused wells was 0.839 ug/l. Due to the low levels of C-8 found at the Dry Run Landfill, the private water supply survey was not extended by the GIST to a two-mile radial area- In summary. C-8 was detected in 60% of the private water supply samples collected in the one-mile area. No private water samples in the one-mile radius exceeded the CATT-established C-8 drinking water screening level of 150 ug/l. The widespread distribution of C-8 in private water supply supplies within the one-mile radial area of Dry Run Landfill indicates that air emissions may be the primary migration pathway for C'8 from the Washington Works Facility. This assumption was made due to the lack of groundwater flow into these areas. RECOMMENDATIONS: Under the Consent Order, a significant number of private water supply samples Division of Water and Waste Management Final C.8 GIST Report _page 16 have been collected that document the extent and current concentrations It is of C-8 in whether the groundwater within a one-mile radius of the Dry Run Landfill. unknown of historic or recent air detected in the groundwater are the result Therefore, the GIST recommends that concentrations emission samplaedddaittioenaaclhsalomcpatlieosnsfroomnlyseolnecceti.ve locations to evaluate the trend of C-8 DcounPcoennttrcaotliloencst. The criteria to select repeat sample locations, with the owners' permission, may include: Drinking water wells with dedteectteacbtaleblleevleelvselosf oCf-8C,-8, and Drinking water springs with Springs and cisterns with detectable levels of C-8. The WVDHHR-BPH and WVDEP recommend selecting ten, with at least one or The msaomreplferofmreqeuaecnhccyaftoergosarym, polfintghepsreivlaotceawtiaotnesr fsourpqpuliaerstesrhlyosualdmtphleinngbfeorreo-neevayleuaart.ed. Ssummary ouif Cw--u8 Riwe,sfuul,tws i.n...P.r.i.va,,t,e, Water Supply Systems at the lLaannddffill (1 Mile Radius) Washington 1W"orks-F-a--cil^it.y..a^n,di Li/owc^ail Drinking Water Wells 10 Non-drinking / Unused Wells 28 Springs and Cisterns -10 Division of Water and Waste Management Final C-8 GIST Report Summary of C-8 Results in Private Water Supply Systems at the Wa.^s^h;in^ngt^on wWnorks Facilityv and Local Landfill (2 Mile Radius) Drinking Water Wells -17 Non-drinking / Unused Wells - 35 Summary of C-8 Results in Private Water Supply Systems at the Letart Landfill (1 Mile Radius) " Drinking Water Wells -11 Non-drinking / Unused Welts "19 Division of Water and Waste Management Final C-8 GIST Report page 18 Summary of G-8 Results in Private Water Supply Systems at the Dry Run Landfill (1 Mile Radius) Drinking Water Wells -16 Non-drinking / Unused Wete - 26 Springs and Cisterns -18 Division of Water and Waste Management Final C-8 GISTReport page 19 OHIO PRIVATE WATER SUPPLY SOURCES As a result of C-8 being detected in the Little Hocking Public Water Supply in December 2001, Ohio EPA and DuPont, in addition to the work being performed under the West Virginia Consent Order, agreed to expand the private water supply sources water use survey and C-8 sampling into Ohio within a one-mite radial distance from the Washington Works Facility. Between March and June of 2002, Potesta Associates, Inc. personnel performed a door-to-door well survey and collected samples from private water supply wells, springs, and cisterns. The samples were collected following the protocols established by the multi-media Consent Order between DuPont, the WVDEP, and the WVDHHR-BPH. Representatives from the Washington County Health Department, Ohio Department of Health, or the Ohio EPA accompanied Potesta Associates, Inc.'s personnel during the initial door-to-door well survey. In August 2002, DuPont submitted a report to the GIST and Ohio EPA documenting the well survey and C-8 sample results within the one-mile radial area. A total of 69 samples were collected from drinking water wells, non-drinking water wells, unused wells, springs, and cisterns. The C8 concentrations measured for drinking water wells ranged from non detect (<0.01 ug/l) to 8.59 ug/l, while a single spring used for drinking water was 1.29 ug/l. The highest concentration of C-8 from the category of non-drinking water wells and unused wells was 16.9 ug/l. C-8 was detected in all the springs and cisterns sampled within the one-mile radius, including a concentration of 23.6 ug/l in a spring used for livestock. Overall, a total of nine samples collected in the one-mile radius had concentrations of C-8 above 10 ug/l. Because some of these higher concentrations of C-8 were detected at the outer limit of the one-mile radius, DuPont agreed to expand the sampling effort in Ohio to two miles from. the Washington Works Facility. The private water supply survey and C<-8 sampling within the one- to two-mile radius of the facility were completed in September of 2002. The results were documented in a report submitted by DuPont to the GIST and Ohio EPA in December 2002. A total of 63 samples were collected and analyzed for C-8, including SO drinking water wells. The C-8 concentrations measured in drinking water wells ranged from non detect (<0.01 ug/l) to 6.5 ug/l. No cisterns and springs sampled in the two-mile radius were used for drinking water. The highest concentration of C-8 from non-drinking water wells or unused wells was 8.68 ug/l. One spring sampled for C-8 had a concentration of 3.02 ug/l. Overall, no concentrations of C-8 were detected above 10 ug/l within the one- to two-mile radius. In summary, C-8 was detected in approximately 94% and 77% of the private water supply samples collected in the one- and two-mile areas, respectively. In general, the concentrations of C-8 are lower in the two-mile radius area as compared to the one-mile radius. Because measured concentrations in the two-mile radius indicated a decreasing trend in distance from the Washington Works Facility, the Ohio EPA and DuPont determined that additional sampling beyond the two-mile radius was not necessary. No private water supply samples in the one- or two-mile radius exceeded Division of Water and Waste Management page 20 ______ Final C-8 GIST Report ,...... ,, - ^ level of 150 ug/l, The wide spread CATT-established C-8 drinking water screening along with the lack of a groundwater the distribution of C>8 in private water sources, that air emissions are the primary migration pathway of C-8 from the Wpaatshhwianyg,toinndiWcaotrekss Facility to adjacent areas in Ohio. RECOMMENDATIONS: request of the Ohio EPA, DuPont has collected a significant number of At the private water supply samples in Ohio that document the extent and current within two miles of their concentration of C-8 in groundwater, springs, and cisterns, has been sampled once, and it is currently Washington Works Facility. Each location concentrations detected in private water sources are unclear as to whether the historic air emissions or air emissions in the last couple of years. that reflective of C-8 concentrations, the Ohio EPA recommends the following TDhueProenfot rceo, ltleocet vaadlduiatitoentahlestarmenpdleosf with the owners' permission from categories of private water sources: Drinking water wells with detectable levels of C'8, Drinking water spring withwditehtedcettaebclteablelevellesveolfsCo-f8.C-8, and Non-drinking water wells detectable levels of C'8. Springs and cisterns with The Ohio EPA recommends selecting at least ten locations with one of more Subsequently, the sfraemqupelenscyfroomf seaamcphlincgatewgilol rbyeforer-qeuvaalruteartleydsabmy pthliengOhfoior oEnPeAyeaanrd. DuPont. Ohio 1 IVIile Radius 25 8 515 g 10 . Drinking Water Wells -18 Non-drinking / Unused Wells- 30 Springs and Cisterns - 21 Division of Water and Waste Management 21 Final C'8 GIST Report Ohio 2 Mile Radius Drinking Water Wells-50 |L B . . . Non-drinking / Unused Wells - 9 Springs and Cisterns - 4 Division of Water and Waste Management page 22 Final C<GIST Report WEST VIRGINIA PUBLIC WATER SUPPLY SOURCES Public Water Supply Sources (PWSSs) in West Virginia along the Ohio River Washington were sampled at various points upstream and downstream of the Initial sampling of DuPont PWSSs within a Works Facility pursuant to the Consent Order. of the facility began in December 2001. upstream and ten miles downstream the sample area was expanded to include one-mile Based on the C-8 concentrations measured, miles upstream of the facility and 54 miles downstream. PWSs located as far as seven Sampling efforts between January 2002 to March 2003 resulted in the following findings: Public Water System River Miles from Washington Works Sampling Dates Well Field Re$u/te rc-8^/9 Distribution System Results (U-QfJg/l) Well #1:0.0686 to 0.0746 Parkersburg Well#2:ND Mar and Apr Well#3:ND NQ Water -7 2002 Well#4:ND Department Well#5:ND Btennerhassett Island State -1 Praairlks DuPont Washington 0 Works Facility Jan 2002 Jan 2002 Mar 2003 Well #1:0.165 AM07-P.W01: NQ to 0.335 A008-PW01: 0.308 to 0.499 AX13-PW01: 0.721 to 1.42 Not tested Not tested General Electric 1.5 Lubeck PSD 4.5 Jan,Feb.and Apr2002 Jan 2002 to Feb 2003 Well #3:1.75 to 1.87 Well A: 0.683 to 0.938 Well B: 0.443 to 0.61 Well C: 0.398 to 0.592 Well D: 0.397 to 0.758 Well E: 0.332 to 1.21 Well F: 0.283 to 1.04 Not tested 0.6 to 0.69 Not tested ND Bellville Hydro Electric 14 Jan 2002 Recreation Well#1:ND Well#2:ND Ravenswood 31 Mar 2002 Well#3:ND NQ Municipal Water Well#4:ND Works Well#5:ND Mason County 45 PSD--Letart Jan, Mar, and Apr2002 Well#1:NQ Well #2:0.0618 to 0.0838 Well #3:0.063 to 0.102 Not tested Division - of W->- * - a t e r an- d Wa-st*e MM-at.n.ageAmmeQnnt Final C-8 GIST Report page 23 Racine Locks 48 and Dam New Haven Water 54 Department Jan 2002 Apr 2002 Not tested Weim:NQ 0.518 ND * A negative stream mile value refers to a location upstream from the Washington Works Facility. A positive number refers to a location downstream from that facility. ** ND refers to a "Non Detect" concentration that is at or below the laboratory's minimum detection limit. The listed concentration can vary by instrument and time; however, the Non Detect concentration for C-8 for this period of time is 0.01 ug/l. *** NQ refers to "Not Quantifiable." It Is a concentration that is below the laboratory's minimum detection limit and is therefore below the level of quantification. The Not Quantifiable concentration for C-& for this period of time is 0.05 ug/l. Upon completion of the C-8 Assessment of Toxicity Team (CATT) study establishing a drinking water screening level of 150 ug/l for C-8, sampling efforts were discontinued for General Electric, Parkersburg Water Department, Blennerhassett Island State Park, Bellville Hydro Electric Recreation Plant. Ravenswood Municipal, Mason County PSD--Letart, Racine Locks and Dam, and New Haven Water Department based on the measured low concentrations. Sampling was continued at the DuPont Washington Works Facility and Lubeck PSD on a quarterly basis to continue to evaluate trends in C-8 concentrations. CONCI.USION$: The completion of the groundwater studies and sampling efforts performed as a part of the C-8 GIST study have resulted in the following conclusions regarding the source of C-8 in the West Virginia PWSSs: * Parkersburg Water Department and Blennerhassett Island State Park: It is believed that the C-8 levels are transported from the DuPont Washington Works Facility via air emissions. Please note that C-8 transported in air emissions a'nd deposited on surfaces is likely to be mobilized by precipitation and migrate via water transport to surface and/or groundwater. * DuPont Washington PSD: It is believed that the C-8 levels are transported via air emissions, and from groundwater migration from C-8-containing materials in the on-site Solid Waste Management Units at the Washington Works Facility. General Electric: It is believed that the C-8 levels are transported from the DuPont Washington Works Facility via air emissions associated with the infiltration of precipitation or from production-well-induced recharge from the Ohio River impacted with wastewater discharges from the DuPont Washington Works Facility. * Lubeck PSD: It is believed that the C-8 levels are associated with pumping-induced recharge of surface water from the DuPont Washington Works Facility's wastewater discharges to the Ohio River and possibly via air deposition. Division of Water and Waste Management Final C-8 GIST Report _ page24 Mason County PSD--Letart: It is believed that the C-8 levels are derived from pumplng-induced recharge of surface water from DuPont Washington Works Facility's wastewater discharges to the Ohio River, Racine Locks and Dam: It is believed that the 08 levels are derived by pumping- induced recharge of surface water from the DuPont Washington Works Facility and/or the Letart Landfill leachate discharges to the Ohio River. RECOMMENDATIONS: Considering this data, it is the GIST'S recommendation that DuPont continue the following for the PWSSs: Lubeck PSD, DuPont Washington Works Facility, and General Electric: Quarterly sampling of wells for two years to ensure that C-8 levels are being maintained or reduced. Conduct a limited field investigation to determine the extent and concentration of C-8 in soil at the Lubeck PSD in the vicinity of their production wells. When the soil sample results are available and the data is evaluated, the GIST will determine what additional sampling activities are necessary to complete the investigation. DuPont will submit a report documenting the sampling investigation and the C-8 results to the GIST when the results are finalized. After two years, the sampling program will be re-evaluated. Blennerhassett Island State Park and Mason County PSD--Letart: Annual sampling for a two-year period to ensure C-8 levels are being maintained or reduced. After two years, the sampling program will be re-evaluated. Racine Lock and Dam: Annual sampling for a two-year period to evaluate levels of C-8 due to the upstream proximity of the Letart Landfill, and to ensure that C-8 levels are being maintained or reduced. After two years, the sampling program will be reevaluated. Parkersburg Water Department, Bellville Hydro Electric Recreation Plant, Ravenswood Municipal Water Works, and New Haven Water Department: No further action is deemed necessary at this time. Division of Water and Waste Management page 25 Final C-8 GIST Report OHIO PUBLIC WATER SUPPLY SOURCES Objectives and Efforts required DuPont to perform Task A of the GIST Team along the Ohio River. As a result, the well of the public water supply sources Association Public Water System was sampled for C-8 sampling field for the Little Hocking Water sampling results within the well field and subsequent in December, 2001. The the GIST to expand the area of monitoring to include public water Facility. monitoring allowed 57 miles down the river from the Washington Works in the resulted sSyasmtepmlinsgfivefefomrtislebs eutpweaennd December 2001 to February 2003 have f^oolilioowwiinn^g fiinnduiinigas": Public Water System River Miles from Washington Wwks Sampling Dates Well Field Results (C-8/jg/l) Distribution System Results (C-Bpg/l) Little Hooking Water Association .0.5 Dec 2001 Jan, Feb. Mar, Apr, Aug.and Oct 2002 Feb 2003 Well #1:1.82 to 3.65 Well #2:2.07 to 4,26 Well #3: 0.42 to 0.952 Well #5: 5,69 to 8.58 1.82 to 4.29 City of Belpre -4.6 Feb, Mar, and Apr 2002 Well #1:0.0995 to 0.13 Well#2;NQ Well #3: 0,12 to 0.141 Well #4:0.101 to 0.133 Well #5: 0.103 to 0.111 0.081 to 0.12 Tuppers Plains/ Chester Water District 14.15 Feb. Mar, Apr, Jut, and Oot2002 Feb 2003 Welt #1:0.486 to 0.726 Well #2: 0.235 to 0.417 Well#3:NDtoNQ Well #4; ND to 0.076 Well #5: 0.201 to 0.297 Well #6: 0.433 to 0.649 0.24 to 0.363 Well#1:ND Village of 51.15 Mar 2002 WWeellll##23:;NNDD ND Racine Village of Syracuse Village of Pomeroy 56.9 56.9 Mar and Apr 2002 Mar and Apr 2002 North Well: 0.208-0.491 South Well: ND Well#1:ND . Well #2: ND to 0.06 Well #4: 0.071 to 0.085 ND 0.063 to 0.066 mile value refers to a location upstream from the Washington Works Facility. A * A negative stream a location downstream from that facility. detection limit. laboratory's minimum ** ND repfeorssittiovea n"uNmonbeDrerteefcetr"s ctooncentration that is at or below the the Non Detect concentration The listed concentration can vary by instrument and time; however, for C-8 for this period of time is 0.01 ug/l. concentration that is below the laboratory's minimum detection *"* NQ relifmeirtsatnod"NisotthQerueafnotriefiabbelleo."w tItheis laevel of quantification. The Not Quantifiable concentration for C-8 for this period of time is 0.05 pg/l. Division of Water and Waste Management page 26 Final C-8 GJST Report Upon completiorr of the CAsTaTmsptluindgy ienffworhtischwea rderdiniskicnogntwinauteerd sfcorretehneinCgitylevoef l of 150 ug/l for C-8 was established, Villages of Racine, Syracuse, and Pomeroy. However, quarterly Belpre and the the Little Hocking Water Association and the Tuppers sPalaminpslinWgawtearsScyosntteinmusedinfoorrder to further evaluate C-8 concentration trends. CONCLUSIONS: completion of the groundwater modeling and sampling efforts performed as part The of the GIST study have resulted in the following conclusions being drawn systems: concerning the source of C-8 contamination in Ohio public water Little Hocking: Mainplyuamirpdinegp-oisnidtiuocnefdrroemchWaragsehionfgstuornfaWceorwkasteFracciolintyta'smsitnaactkion from dWisacshhainrggetos;n hWoowrekvserF,acility wastewater discharges to the Ohio River may have also contributed. Be/pre: Air deposition from Washington Works Facility's stack discharges. Pumping-induced recharge of surface water contamination from Tuppers Plains: Washington Works Facility wastewater discharges to the Ohio River. Village of Racine: No discernible contamination. Pumping-induced recharge of surface water contamination f roSmyrtahceuWseasahnidngPtoomneWrooyr:ks Facility and/or the Letart Landfill leachate discharges to the Ohio River. Considering the public water system data, and the elevated levels of C-8 noted that DuPont .in the Test Well 4 Investigation (see below), the GIST recommends production wells and entry point for the Little continue quarterly sampling poufbbloicthwtahteer system for two years. Also. annual sampling Hocking Water Association System (production wells and entry point) to ensure fcoorntthineuTeudprpeedrusctPiolaninosf WC-a8teisr advised. At this time, no further action isAdfteeermtwedo years, necessary for the Villages of Belpre, Racine, Syracuse, or Pomeroy. the sampling frequency will be re-evaluated. LITTLE HOCKING WATER ASSOCIATION WELL FIELD INVESTIGATION: In addition to sampling Little Hocking Water Association's production wells, wells) within the Little periodically sampled ten test wells (/.e., monitoring of C-8 is less than 2 ug/l in DuPont has Hocking Water Association well field. The concentration wells exceeded 4 ug/l. In one test well, TW-4, most of these test wells; however, a few at 37.1 pg/l in January of 2002. Subsequent tshaemcpolinncgenotfrTatWio-n4 oinf dCi-c8atwesasgemneearsalulyreddecreasing concentrations of C-8 at 33.3 pg/l Division of Water and Waste Management Final C-8 GIST Report pg/1(April 2002), 12.3 ug/l (August 2002), and 14.5 ug/l (October pg/l, (March 2002), 28.7 2003, the concentration in well TW-4 rose to 22.5 2in0d0i2ca).tinHgopwoesvseibr,leinsFeeabsorunaarlyeffects on this well. of the Ohio EPA. DuPont conducted a field investigation in the 30th, Little At the request Hocking Water Association Well Field between August 19th and August and concentration 2002. The purpose of this investigation was vicinity to determine the extent of test welt TW-4. Groundwater sample in soil and groundwater in the investigation ranged from non detect (<0.01 pg/l) to 78.0 of C-8 results collected during this detected in soil from the well field is 170 ug/l of C-8. The highest C-8 concentration documenting the results of the investigation was submitted by DuPont ug/kg. A report the Ohio EPA and GIST in April of 2003. Once an evaluation of this report is additional activities'are - to complete, the Ohio EPA and DuPont will determine what necessary to compete the investigation. Division of Water and Waste Management Final C-8 GIST Report OHIO RIVER SAMPLING conducted to determine the concentrations Ohio River ss ampling activities were collected from 12 river transects and extent of C-8 in the Ohio River. Samples were sampled at many of the locations, and 19 locations, and multiple depths were sampling locations were approximately 28 mites upstream The most distant river from the DuPont Washington Works Facility to determine the DuPont and 46 miles downstream background levels of C-8, Samples were collected adjaceTnhtetofiannadl pbaerltoowf the river Plant to determine the concentrations of C-8 in the river. determine if concentrations of C-8 were sampling was adjacent to the Letart Landfill to present there. At the end of the Ohio River sampling, 49 water samples were taken, with the following results: ' ' !"--- IMiimharof T Depths ' includes a duplicate sample. Division of Water and Waste Management Final C-8GIST Report page 29 CONCLUSIONS: No river sample exceeded the CATT'established C-8 drinking water screening level of 150 ug/l for any of the Ohio River samples. No additional river sampling is thus required as a part of the Consent Order; however, sampling should continue as part of the Washington Works Facility and Letart Landfill NPDES outfall monitoring. Division of Water and Waste Management Final C-8 GIST Report SURFACE WATER AND GROUNDWATER MONITORING page 30 It should be noted that site location maps, top-of-groundwater maps, and site geological maps are located in Appendix A, and that a complete set of groundwater data (in both table and graph form) is located in Appendix B. These data included with this final GIST report ends with the March 2003 sampling. The hydrological information is from the February 2003 Summary Report. It should also be noted that the data displayed here (both historical and recent) have been generated using several different analytical methods. Prior to .1991, DuPont performed the C-8 analysis at the DuPont Experimental Station in Wilmington, Delaware. In 1991, when the Resource Conservation and Recovery Act (RCRA) Verification Investigation was conducted at the Washington Works plant, the analysis was contracted to the CHzMHill Laboratory in Montgomery, Alabama. Both of these laboratories used.a Gas Chromatography-Electron Capture Detected-based analytical methods with detection limits for C-8 that ranged from 0.1 to 1.0 ug/l. CH;,MHill conducted the C-8 analysis into the fall of 1998 when the laboratory ceased operation. At that time, the analytical work was transferred to Lancaster Laboratories, in Lancaster, Pennsylvania. DuPont continued to use this facility until October 2001, when development and testing was completed on a new analytical method utilized by Exygen Research, Inc., located in State College. Pennsylvania. This method uses a Liquid Chromatography-Tandem Mass Spectrometry. DuPont adopted the regular use of this method in November of 2001. HISTORICAL WORK: Before any assessment could be made of the groundwater and surface water at the four DuPont locations, a summary of the historical data was compiled. This was submitted by DuPont in January of 2002 in the document, Compilation of Historical C-8 Data, DuPont Washington Works Facility, Main Plant, and Landfills. This report included a brief historical, geological, and hydrogeological overview of the four sites (Washington Works Facility, Local Landfill, Dry Run Landfill, and Letart Landfill), and identified three data gaps: the need for additional groundwater monitoring wells, continued refinement of the groundwater model at the main plant, and the need to evaluate the Ohio River surface water. This report also included location maps for the four sites, multiple geological cross-sections, four top-of-groundwater maps for each facility, and construction details for the groundwater monitoring wells. Many of the locations were sampled only once; however, samples had been collected from other locations on as many as 17 occasions. The information submitted on the four sites' historical sampling locations was as follows: i? Division of Water and Waste Management IU*1 ^-W g- V > , -^ y Facility Outfalls Sampled Washington Works 2 Local Landfill 6 . Dry Run Landfill 1 Letart Landfill 2 Other Surface Water Locations Sampled 2 2 5 6 Groundwater Monitoring Welts Sampled 62 4 9 Zone A: 3 Zone B: 0 ZoneC: 1 ZoneD-E: 3 Zone:F: 4 On-S/te Drinking Water Locations Sampled 4 0 0 0 To satisfy Task B of the GIST requirements, regular surface water and groundwater monitoring for C-8 then began in December of 2001. At first the modified to quarterly groundwater sampling was monthly; however, this interval was The surface water was (and still once the initial four sampling events were conducted. including the-historical data, the four DuPont sites ihsa)vseambepelendseaamcphlemdofnotrhC. -T8ofodratthee, following number of locations and occasions: Facility Water Type Washington Works Surface Groundwater Local Landfill Surface Groundwater Zone A Groundwater Zone B Groundwater Zone C Qroundwater Zone D Dry Run Landfill Surface Groundwater Zone A Groundwater Zone B Groundwater Zone C Letart Landfill Surface Groundwater Zone A Groundwater Zone B 1 Groundwater Zone C Maximum Number of Sample points G 20 6 4 1 3 1 8 3 12 1 6 3 0 ' -'" 1 Maximum Number of occasions 26 19 23 13 2 2 2 22 18 18 2 25 21 0 10 Division of Water and Waste Management Final C.8 GIST Report page32 To satisfy Task C of the GIST requirements, it was also recognized that all of the The following four DuPont locations required additional groundwater monitoring weds. wells were added in August of 2002: Maximum depth \ Drilling rig Diameter Screen length These new wells, first sampled in October 2002, fill in missing gaps of the four in the DuPont well fields. They provide a complete encirclemmenigtrating from any of the groundwater locations, and should identify any C-8 groundwater plumes four sites. RESULTS AND CONCLUSIONS: DRY RUN LANDFILL: Landfill is located west of the town of Lubeck, on the headwaters of The Dry Run in southwestern Wood County, The site is about eight miles southwest of the 81* Dry Run the Local Landfill, at 39' 11' 07" North Latitude and landfill flows to the Washington Works Facility and 41' 18" West Longitude. Dry Run begins at the toe of the and which flows into the Ohio northwest. It is a tributary of the North Fork of Lee's Creek, Appalachian Plateau, and is underlain by The landfill is situated on the dissected which are of late Pennsylvanian or River. the sandstones and shales of the Dunkard Group, operation in 1986, and the central portion is Permian age. The Dry Run Landfill began Division of Water and Waste Management Final C-8 GIST Report Jpa9g.33 _ still active and operates under WV-NPDES Permit No. WV0076244. The upper (southeastern) portion of the landfill is closed and covered with a soil and vegetative cover. The lower (northwestern) portion also closed and is covered by an engineeredlandfillcap. The Dry Run Landfill is about 17 acres in size, and is approximately 690 feet wide and 1500 feet long, with an elevation rise of about 250 feet. It is oriented in a southeast and northwest direction, and is constructed in an old, v-shaped valley above Dry Run. Physically, the site is a long grassy slope of fill material surrounded (and situated on) the small valley's native rock and soil. The site borders no highways. residential, or industrial areas. In the late 1980s, waste sludge materials from an anaerobic digestion pond (from the main plant) was placed in the upper, southeastern side of the landfill. Geologically, the bedrock beneath the landfill is comprised of individual layers of shale, silty clay, and sandstone and siltstone. Within this sequence the three dominant aquifers are nearly continuous sandstone and siltstone. These have been labeled by DuPont--beginning with the October 2002 groundwater monitoring report--as Zone A, Zone B, and Zone C, with Zone C being the deepest. Zone B is considered the main groundwater zone, and has eleven wells screened through it--five of these wells are newly constructed and have only been sampled on one occasion. Zone A has three wells screened within it, and Zone C has only one well. The Zone A groundwater flows to the west-northwest, and has a gradient of 0.055 vertical feet per horizontal foot. The zone varies in depth between zero (to the northwest) and 200 feet deep (to the southeast). It is between 25 and 35 feet thick. The C-8 plume, based on three wells, appears to be moving to the west-northwest and down the axis of Dry Run. Of the three Zone A groundwater monitoring wells, one--located northeast of the Dry Run Valley--has consistently contained concentrations below 1 ug/l. A second well. located to the southwest of the valley, contains concentrations of between 0.2 and 5 pg/l. The third well, DRMW-13, has contained the highest concentrations of C-8, ranging from 3.6 to 20.9 ug/l. This well is located in the middle of Zone A and the Dry Run valley. The Zone B groundwater flow appears to be moving in an arc that varies between a northwestern direction in the upper southeastern portion of the site, and in a western direction in the lower western part of the site. The zone is about ten feet thick with a gradient between 0.006 and 0.023 vertical feet per horizontal foot. Zone B varies in depth from between 220 feet deep under the southeastern portion of the site to just a few feet below the surface at the toe of the landfill. It may be breached by the Dry Run surface stream northwest of the landfill. Alt of the wells surrounding Zone B were sampled in October 2002. Only six wells in the down-gradient western part of the landfill contained detectable concentrations of C-8, The well which consistently contains the highest concentrations of C-8 is well DRMW-13A, located directly in the Dry Run Valley and is adjacent to well DRMW-13. The C-8 concentration in well Division of Water and Waste Management Final C-8 GIST Report page 34 DRMW-13A is less than in well DRMW-13; however, it does seem to indicate that Zone B's plume is also moving directly down the Dry Run valley. As stated previously. Zone C is the deepest of the three groundwater zones. This zone is only penetrated by one groundwater monitoring well, DRMW-21B. Zone C is located approximately 120 feet below the Dry Run valley, and it has not been determined if it extends to the southeast and under the landfill. Zone C is at least 45 feet thick, and may be confined, as the groundwater surface in the well extended above the well's screen and the top of the sandstone-siltstone layer in the October 2002 sampling. Without additional wells penetrating Zone C, it is impossible at this time to determine the zone's extent or the groundwater flow direction and gradient. Well DRMW-21B contained no detectable concentrations of C-8 on the two occasions it was sampled, so it is presumed at this time that there is no C-8 in Zone C. It is difficult to make any kind of conclusions regarding the surface water at the Dry Run Landfill because many of the sampling locations have been consistently dry during much of 2002. It is also difficult to make statements regarding the concentrations of C-8 found to date because these concentrations vary so much from sample location to sample location. The highest.concentration of C-8 found at the surface sampling points is the Dry Run leachate location, where the concentrations of C-8 has ranged between 109 and 704 pg/l since December of 2001. The leachate is collected and hauled to the Washington Works Facility's treatment system, and does not discharge into Dry Run. A further breakdown of the Dry Run Landfill sampling data is as follows: Dry Run Landfill Surface Water: (units are ug/l) Sample Point Outlet 001 Outlet 003 Outlet 004 Property Boundary Number of 15 3 2- 12 samples Minimum C-8 17 6.77 0.7 Maximum C-8 68.5 25.3 158 0.88 39 Average C-8 58.57 17.39 79.35 11.3 Stream #1 11 0.54 1.63 1.07 Stream #2 11 4.6 87 40.29 Dry Run Leachate 12 27.4 704 205.59 Pond Under Drain 8 29.3 99,7 50.98 Dry Run Landfill Groundwater Zone A: (units are pg/1) Sample Point DRMW-12 DRMW-13 DRMW-15 Number of samples 13 12 10 Minimum C-8 <0.1 3.6 0.25 Maximum C-8 0.134 20.9 5.0 Averaae C-8 0.08 12.16 3.74 Division of Water and Waste Management Final C-8 GIST Report a No Detect concentration of "<0.1" was calculated as zero. Note: For the purposes of averaging these values, a No Detect concentration of "<0.1" was calculated as zero. Note: For the purposes of averaging these values, Dry Run Landfill Groundwater Zone C: (units are pg/l) Sample Point DRMW-21B Number of samples Minimum C-8 Maximum C-8 Average C-8 <0.1 <0.1 <0.-t LETART LANDFILL: Landfill is located about 0.6 miles north of the small community of The Letart in northern Mason County. It is 46 miles down the Ohio River from DuPont's 81' 55' 43" Letart Facility, and is located at 38' 54' 15" North Latitude and the dissected WWaessht iLnogntognituWdoe.rkTshe site--like the Dry Run Landfill--is situaantdedshoanles of the Dunkard Appalachian Plateau. Bedrock consists of directly the sandstones west of the Ohio River, which is here flowing Group, It is sited in a valley that is landfill (and across the hill behind the landfill) is the north-flowing nBorirnthk.erWReusnt. oTf htheeLetart Lapndefrimll awnaesntolypecrlaotseedd abnydincslotaslelidngunandeernWgiVn-eNerPeDdEmSuPltie-rlamyietr No. WV0076066, and was Division of Water and Waste Management Final C8 GIST Report _ .._ geosynthetic and soil cap in 2001, The permit requires quarterly groundwater monitoring, surface water monitoring, and cap maintenance. page 36 Physically, the Letart Landfill is tear-shaped. It is approximately 1,400 feet long, and tapers in width from a maximum of 850 feet along its northern edge to a narrow point at the Ohio River. The elevation difference between the wider, higher northern boundary and the lowest elevation point near the Ohio River, is about 140 feet. The landfill itself is covered with grass. There are no highways, residents, or businesses adjacent to the landfill; however, U.S. Route 33 parallels Brinker Run, which is located about 700 feet to the west. This is a rural part of West Virginia, and there are no residents and businesses along this section of the highway. Geologically, the bedrock beneath the landfill is comprised of individual layers of shale, silty clay, and sandstone and siltstone. There are, depending on how and where they are counted, between four and six aquifers at this site, which have been labeled by DuPont as Zone A, Zone B, Zone C, Zone D, Zone E, and Zone P. Zone A is the shallowest of these aquifers, and is monitored by three groundwater monitoring wells. Zone B contains no wells, and Zone C contains only one well. Zone D-E contains five groundwater monitoring wells, and Zone F, the deepest and dominant aquifer at this site, has nine wells screened through it. Groundwater Zone A is exposed near the surface, and varies between 25 and 60 feet thick. It is continuous in nature, but apparently contains interbedded discontinuous shale, sandstone, and siltstone lens. There are only three wells, screened in Zone A. These wells are all located relatively close together and more-or-less in a straight line along the northwestern edge of the landfill; Given these limitations, the October 2002 groundwater sampling gave the appearance of a north groundwater flow and a plume that centered on well LMV\M, the central-most of the three wells. Of the three Zone A wells, LMW-1 has the highest concentrations. These concentrations have varied since April 1996 between 1,700 and 30,500 ug/l. Well LMW-8 has the next-highest concentrations, and these concentrations have varied between 280 and 4,020 ug/l. Well LMW-7 has displayed the least concentrations of C8 in these wells since October 1999 between 158 and 567 ug/l. There are no wells screened through Zone B. However, judging from the crosssection produced when the deeper wells were drilled, this zone reaches its maximum thickness of more than 70 feet at the northern-most tip of the landfill, where it is combined with Zone C. Zone B pinches out (disappears) completely as one moves down the landfill toward the river, Zone C appears to be continuous across the site. It is approximately 15 to 25 feet thick under the main and southern portions of the landfill, and combines with Zone B in the northern part of the site. Only one well is screened through Zone C, so no assessment of a plume or groundwater flow and direction can be made. This well, Division of Water and Waste Management Final C-g GIST Reiaort page 37 LMW-3, is located near the very toe of the landfill and in close proximity to the Ohio River. This well had a concentration of 2,270 ug/l C-8 in May 2002. Zone D-E is the most complex of the Letart water-bearing zones. These zones appear to be combined in the southern, central, and northern portions of the site. They are separated by a shale layer in the western and possibly the central portion of the landfill. It is also possible that Zone D may be completely missing in the northern and northeastern portions of the site. The thickness of this zone can range between 10 and 40 feet. Zone D-E, as mapped by DuPont in October 2002, has a gradient of 0.026 vertical feet per horizontal foot with a groundwater flow direction to the south-southwest. There are five groundwater monitoring wells screened through Zone D-E, Most of these wells are located near the southern toe of the landfill: Of these five wells, two were only recently installed, and long-term data exists for three of the wells. LMW-4 has consistently contained the highest concentrations of C-8. These concentrations have ranged from 172 to 2,840 ug/l. All five of the Zone D-E groundwater monitoring wells sampled in October of 2002 indicate high C-8 concentrations under the .main part of the landfill, with a plume flowing due south and through LMW-4. Two wells, located just east of LMW-4 contained much lower concentrations of C-8. As previously stated, groundwater Zone F is believed to be the dominate aquifer at the Letart Landfill. This zone is the deepest of the six aquifers. It is continuous across the site ranging from 30 to 70 feet thick. The groundwater within the zone flows to the south-southeast. This zone has a gradient of between 0.030 to 0.057 vertical feet per horizontal foot. There are nine groundwater monitoring wells screened through Zone F positioned all around the landfill. Six of these were sampled prior to October 2002, and seven were sampled in October of 2002. These wells project a possible C-8 plume moving south down the center of the landfill. The lowest concentrations are to the west of the landfill, where there is one concentration of 105 ug/l in well LMW-14B. The highest C-8 concentration is at the very toe of the landfill at well LMW-5B, which has consistently contained high concentrations since it was installed more than a decade ago. Since July of 1999, these concentrations have ranged between 592 and 2,280 pg/l. Zone F well LMW-2A contains high concentrations of C-8 that have varied between 242 and 913 pg/l since September of 1994. In addition, this well is located on the extreme northern edge of the landfill, away from the anticipated plume direction. Welt LMW-12, drilled just to the west of LMW-2A, was dry during the October 2002 sampling event. These two wells should be monitored closely to determine groundwater flow direction and if there is a plume moving off the site to the north. It should also be noted that there is a private water source (GERLACHIBA) north of the Letart Landfill where a small concentration of C-8 was found- Division of Water and Waste Management Final C-8 GIST Report page 38 It should be noted that, due to the installation of the synthetic cap, stormwater contribution to the groundwater flow has been lessened under the landfill. It is probable that the contribution of C-8 to this flow has remained stable. Less groundwater volume combined with a steady contribution of C-8 will equal a higher concentration of C-8 in the groundwater. This scenario appears to have occurred at the Letart Landfill. The site should be monitored closely to ascertain trends in C-8 concentrations. The surface water at the Letart Landfill has been sampled for C-8 at six locations. The data for some of these points is very intermittent. While most of these concentrations are very low, C-8 has been found at the two Brinker Run sampling locations. The two highest concentrations were found at the southern toe of the landfill, at Outlet 002 (the Leachate Basin) and the Cap Runoff location, both of which indicate increasing concentrations of C-8. Outlet 002 and the Cap Runoff have had concentrations as high as 3,240 and 415.6 ug/l, respectively. A detailed breakdown of the surface and groundwater data is as follows: Letart Landfill Surface Water: (units are fjg/l) Sample Point Outlet 002 Outlet 003 Stormwater Run Off Number of samples 18 6 1 Minimum C-8 4:52 0.06 50.9 Maximum C-8 3240 0,239 50.9 Average C-8 899.22 0.21 Route 33 Stream 13 0.7 3.92 1.96 Brinker Run 2 0.06 0.247 0.154 Cap Runoff 6 65.1 415 225.18 Letart Landfill Zone A Groundwater: (units are ug/l) Sample Point LMW-1 LMW-7 LMW-8 Number of samples 21 20 20 Minimum C-8 60 0.1 280 Maximum C-8 30,500 567 4020 Average C-8 14,896.57 233.57 2499 Letart Landfill C Zone Groundwater: (units are pgA) Sample Point DRMW-3 Number of samples 8 Minimum C-8 <0-1 Maximum C-8 2270 Division of Water and Waste Management Final C'B GIST Report pagejg Note; For the purposes of averaging these values, a No Detect concentration of "<0.1" was calculated as zero. Letart Landfill Zone P Oroundwater; (units are psW Sample Point LMW2A MW5B LMW-6 LMW-9 Number of samples Minimum C-8 Maximum C-8 Average C-8 23 50 990 496.8 22 340 2280 1161.9 12 9.4 30 17.49 9 0.2 0.91 0.65 LMW10 5 O-niiCK*l . 0.298 0.165 LMW- 11 8 0.058 0.159 0.110 LMW' 12 0 LMW13B 2 0.09 0.149 0.1223 LMW14B 2 70.4 105 87,7 LOCAL LANDFILL: Landfill is located immediately south of the Washington Works Facility is in northTwheesLteorcnalcentral WoodLaCtiotuudnetya. ndIt 8c1o'n3s9is'ts16o"fWthereset Lsoenpgairtautdeec. loItsiesdsciteulalst,edanodn sandstones and ltohceadteisdsaetct3e9d' A15p"p5a4la"cNhoiarnthPlateau, consisting of Du1n9k6a4rdinGtorothuep 1980s, and were shales. The three landfill cells were operated from WV0076538. They are now covered with closed under WV-NPDES Permit No. permeabilitysoil and vegetative cover. The site is in a approximately two feet of low there are a number of residential homes south of the somewhat rural area; however, 892 is just north of the landfill and located between the landfill landfill. State Highway and DuPont's Washington Works Facility, Physically, the three Local Landfill cells are 60 by 140,70 by 110,40 by 60 actually feet in size; however, the landfill cells are irregular in shape and the cells are sited along the tops and sides somf tahlrleere thhiallns, twhehsicehdaimreelnosciaotnesd ijnudsitcsaoteu.thTohfetshee cfelalltsOahrieo River flood plain. Geologically, the bedrock beneath the landfill is comprised of individual layers of Division of Water and Waste Management FriinnaaljwCv'8^GmJSTR,^ej^g,o._rt-^ _ principal aquifers, all of 'shale, silty clay, and sandstone and siltstone. There are four comprised of sandstone and under the overall site, and are (in their October 2002 groundwater monitoring which are continuous siltstone. DuPont has named these to deepest, Zone A, Zone B, Zone C, and Zone D, Zone A is report), from shallowest believed to be the dominant aquifer. 10 to 20 feet thick, and varying in depth between 60 Zone A is usually between is continuous across the site, and has been eroded by an the to 110 feet. This zone that flows out of the landfill area to the west, and then flows to gradient of unnamed stream northwest. Groundwater flow in Zone A is to the north-northwest with a groundwater monitoring wells 0.008 vertical feet per horizontal foot. There are four consistently contained C-8 concentrations that screened in Zone A. Two third of these have LLMW-6, has contained C-8 concentrations below 10 ^ are below 1 ug/L A well, LLMW-4, contains C-8 concentrations up to 79 ug/l. This ^ i:? ug/l. The fourth wellt,hat the Zone A C-8 plume is moving north toward LLMW-4. supports the theory B is generally 5 to 10 feet thick, and between 90 to 130 feet deep. It is is only one Zone surface stream, and grades out to the east. There It contained a C-8 iwneclilssedcrbeyenthede uinntnhaismzeodne, and has only2b0e0e2nasnadmaplNeod tDweitceec. t concentration in March of concentration of 0.0658 ug/l in October information or groundwater flow and gradient data 2003. With only one well, no plume can be generated on this groundwater zone. Zone C is 10 to 20 feet thick, and 90 to 130 feet deep. It is continuous across incised by the surface the entire site. Due to Zone C's greater depth, it has not been and the gradient is 0.0153 vertical feet stream. Groundwater flow is to the northwest, wells are screened in this zone. Each well has been per horizontal foot. Three concentrations ranged from 0.317 to 6.61 ug/l. sampled twice, and the C-8 Zone D is more than 12 feet thick, and is 135 to 170 feet deep. Only one well with No Detect this zone, and has only been sampled twice, no plume information or has been screened in With only one well, concentrations on both occasions. generated for Zone D. groundwater flow and gradient data can be Six sampling locations are used to monitor the surface water at the Local with the highest displayed concentrations of C-8 ranged concentrations Landfill. All of tohcecsuerrloincgataiot nOsuhtlaevt e101 and Outlet LM1. These ug/l in March concentrations 72 pg/l in January 2003, and dropped to 45.4 from 38 ug/l in June 2002 to higher: They were 120 and 81.7 ug/( on the two 2003. Outlet LM1's concentrations are occasions this location was sampled. The Local Landfill data can be further broken down as follows: Division of Water and Waste Management ^; Local Landfill Zone B roundwater: (units are Sampte Wnt LLMW-12B Number of samples Minimum C-8 <0.1 Maximum C'B 0.0658 average C-8 0.0329 Note: For the purposes of averaging these values, a No Detect concentration of "<0.1" was calculated as zero. Division of Water and Waste Management Final C-8 GIST Report Local Landfill Zone D Groundwater: (units are pgA) Sample Point_ LLMW-HB Number of samples^ 2 Minii'rium C-8 <0.1 Maximum C-8 <0.1 Average C-8_ <0.1 iv. WASHINGTON WORKS FACILITY: VVftoninv* - , - - - Washington Works Facility is located just north of the small The DuPont community of Washington and about seven miles west and downstream North Latitude and 81" of 40' 34" West Parkersburg. The facility is located at 39* fl1o6o' d13p"lain. The flood plain here is comprised Longitude, and is sited on the Ohio glacial outwash and River Holocene river sediments (alluvium) overlying the gravel, silt of Pleistocene Group. These sediments are comprised ofSstaatnedRaonudte 892 is baenddroclcaky,ocf othlleuvDiuumnk, aarndd fill. The site is in a sOomhieowRhiavterruisralloacraetead. immediately to the located just south of the plant property. The north of the property. than 100 groundwater monitoring and production wells at the by the There are more Facility. Of these wells, the following 19 wells were chosen WGaISsThitnogbtoensWamorpklesd under the Consent Order: ' '-- - --- ''-"' ------- - T ^ '-,,.:,. _nl consistently been less than 1 ug/l, and another seven Of these less wells, five have than 20 ug/l. Three of the remaining wells have had C-8 concentrations (P08-MW01)--when last have been 60 ug/l; however, one of these wells has only been sampled once, between 20 and sampled--contained 120 pg/l. A fourth well, N04-MW01, but this concentration was 689 ug/l. The remaining three wellsanadll Rco0n4t-aMinWh0i2g,hwciotnhcreenptorartteiodncsoonfcCen-8tr.atTiohnesseasarheigh respectively. wells P04-MW-2, Q04-MW-02, has 46,600, 7,720, and 322,000 ug/l of C-8, At present, six outlets are used to monitor the discharges at the Washington Division of Water and Waste Management lF_innnala^Cv.8vwG,I-S^T. Report ,-^.,_ . _ 2001 Facility. With a few exceptions (one of which was Outfall 005 in November consistently discharged Works 915 ug/l), all of these outlets have had wreitlahtiavecloynlcoewntcroanticoenntorfations of C-8, ranging from ND to 54.9 ug/l. A further breakdown of the Washington Works Facility discharge water and gjrroouulnlduwwoaticeir dua"ti.ai-.is as follows: Washington Works IFacility Surta <?e Water: fun its are pg/S) Sample Pofnt Outlet 001 Outfall 002 Outlet 003 Number of samples 16 25 16 Minimum C-8 2.15 0.118 0.175 Maximum C-8 51.4 8.54 7.13 Average C-8 14.39 3.21 1.544 __ :_" ___!iiim^..^- -^^ ^__-. Note: For the purposes of averaging these values, a No calculated a$ zero. Outfit 005 26 1.43 915 81.15 Outlet 007 18 <0.1 8.56 1.42 Outlet 105 16 3.69 54.9 14.43 Detect concentI--raHt--ioBn, o,,<f: r''^<-0fi.1I"'wwas Note: For the purposes of averaging these values, a No Detect concentration of "<0.1" was calculated as zero. Note: For the purposes of averaging these values, a No Detect concentration of "<0.1" was ''" calculated as zero. Division of Water and Waste Management RECOMMENDATIONS: The first priority at each of the four sites is to continue the surface and groundwater should continue to be monitoring programs. Sampling of the monthly, quarterly, or semi-annually, groundwater quarterly, while the outfall sampling can be either as required by each site's individual NPDES permit. The continuing source of C-8 at the Washington Works Facility is believed to old River Bank be reclaimed digestion pond and from the Facility Investigation, which is originating from a previously Landfill. Currently, the facility is under a RCRA of the GIST that any action addressing these C-8 sources. It is the recommendation of the C-8 sources be deferred to the relative to the investigation or remediation Action Program (CAP). WSEPA-WVDEP RCRA Corrective Division of Water and Waste Management Final C-8 GIST Report GROUNDWATER MODELING Groundwater modeling of the Washington Works Facility's main location was by the United completed independently by DuPont's URS Diamond contractor and modeling was completed using Geological Survey (USGS). URS Diamond's completed using Visual Modflow States Vistas software. The USGS model was boundary conditions. Groundwater Both models were based on similar calibration data and software. The USGS groundwater model did not address groundwater seepage from the groundwater model did address adjacent bedrock aquifers, whereas the URS Diamond both models show close agreement in this seepage. Preliminary analysis of calibrated heads, and rate and volume of groundwater groundwater flow directions, The model data that follows is primarily f r o m the URS Diamond groundwater part of larger modeling flow. USGS groundwater model will be publishedas a Environmental Health Services of mefofodret li.n Tchoerporation with the WVDHHR-BPH, Office (OEMS). URS Diamond model boundary was the alluvium, and into bedrock. 235 The The was 5.0 to 7.9 miles, consisting of 153 rows, in the simulation. In included URS Diamond model domain Fifty-one discharge wells were columns, and 3 cells deep. a major gap in the data occurred due to the beginning stages of building the models, The data gap was eliminated by a great lack of data concerning river bottom geometry. compiled by the Army Corps of abundance of new data obtained from recent surveys projects at the eastern end of the model domain. Engineers for construction QEOLOOY: The alluvium was found to be betweenA6l0luvtoia8l 0aqfueiefterdseeinpthoen mteorrdaecledsoamnadin1s0 to 15 feet deep in the center of the river valley. locally confined by Holocene overbank deposits. were mostly unconfined, with some alluvial aquifers consist of coarse sands and gravel underlain by predominately Ohio River Thohreiszoentally bedded sandstones tohfethPelePisetnoncseynlevaanlliuavniuDmunuknadredr Gthreouripv.eTr.hTehis cgrreoautnedswaagterroduinvdidweatdeoredsivniodet ainppear to exist In the bedrock aquifer. Typically, the permeability of the alluvium was 100 to 300 feet per day. Bedrock with some aquifers were primarily confined, and consisted of Dunkard sandstones aquifers ranged from 0.5 to 5 feet per day. minor limestone. Permeability in of the bedrock the models were 330 feet per day for coarse alluvium, 30 Hydraulic conductivity used and one foot per day for fine alluvium. Hydraulic fceoentdpuecrtivdiatyy ffoorr breewdroorckkedaqaulliufveirusmw,as 0.1 feet per day. Alluvial aquifers oTnhe normal Blennerhassett Island had a hydraulic conductivity of 200 feet per day. hydraulic head of the Ohio pool level of 582 feet above sea level was used for the River. Division of Water and Waste Management Final C-8 GIST Report jogge 46 MODEL CALIBRATION: A total of 50 industrial and ppuubmlicpwinagteart sthuepptilmy ewewlhlsenaresylnoocpattiecdgirnotuhnedwmaotdeerl to the model domain, 44 of which were actively calibration. The well locations elevations were being measured for model domain are: DuPont Washington Works Facility (WV): Blennerhassett Island State Park (WV): GE Facility (WV): Lubeck(WV)PSD: City of Belpre (OH): 13 wells 12 wells 14 wells 6 wells 1 well (Note: Belpre has five pumping wells; their total flow was assigned to one well for the model.) kittle Hocking (OH) Water Well Field (wells PW-1, PW-2, and PW-3 were included in the model. Although well PW>5 was included, no pumping was simulated) 4 wells The mass balance of the groundwater flow model had a total error of less than little error in simulating real world conditions. one percent, indicating very Recharge was estimated to be an average of approximately 8 to 10 inches per calibrated at eight year. according to the USGS model. URS Diamond's model was the USGS agreed, seemed to satisfy inches per year and, as the modeler for Differences in the two figures arose from different conductivity calibrations better. interpretations of possible areas of incised valley bottom fills under the Ohio River. the These areas may have slightly different hydraulic conductive properties from adjacent sediments, Sensitivity analysis was run on three parameters: hydraulic conductivity, analysis indicated that most boundary conductance. This sensitivity assigned to the re-worked roefcthhaerguen,cearntdainritvyear ssociated with the model was in the value Pleistocene alluvium under the Ohio River. CONCLUSIONS: The calibration of both models was tested and highly refined over the course of parties placed high Both models were only slightly different. All The USGS the modeling effort. sophisticated URS Diamond model. confidence in the somewhat more by incorporating some of the data presented in the URS further refined their model Diamond model. groundwater divide in the Pleistocene alluvium under The Ohio River creates a supported by both models, was that the groundwater the river. The principalconclusion, Division of Water and Waste Management page 47 Final C-8 GIST Report divide under the river, along with the pumping rates from the DuPont and neighboring impacted GE Facility wells that draw down a cone of depression, precludes C-8 into either Lubeck the Washington Works Facility from being drawn Little Hocking Water Association well groundwater from PSD municipal well field in West Virginia, or the migrate off-site in the northwest corner of field in Ohio. Some limited groundwater may to GE pumping wells #3 and #4. Sources of C-8 in the the DuPont facility in response Little Hocking Water Association wells, are most likely coming Lubeck PSD and the from the Ohio River and dispersion by ajr. RECOMMENDATION; It is the recommendation of this report that the URS Diamond model be accepted ^ in determining groundwater flow and contaminant >^ as representing real-world conditions transport. . Division of Water and Waste Management Final C.8 GIST Report REFERENCES -E3^ 48 and Herbert P. Woodward. 1968 Geological Map of West Virginia, Cardwell, Dudley H., Robert B. Erwin. Geological and Economic Survey, 1968. West Virginia Alliance between DuPonI and URS Diamond. Letart Landfill Corporate Remediation Group, an Groundwater Protection Plan, SW-NP Permit WV-7606G. DuPwt Washington Works, Parkersburg, West Virginia, January 7,2000. DuPont and URS Diamond, Compilation of Historical Retnediatton Group, an Alliance between Washington Works Site, Washington, West Virginia, January Corporate Data for Washington Works, DuPont 2&0W0&2.. DuPont and URS Diamond, December 2001 Remediation Group, an Alliance between Washington Works Facility and Local, Letart, and Letart Dry Run Corporate Groundwater Monitoring Report for Landfills. Washington, West Virginia, January 2002. . Corporate Remediation Group, an Alliance between DuPont and URS Diamond, Works Plant, Groundwater Washington, West Investigation Quality Assurance Project Plan for Washington Virginia, January 2002. Group, an Alliance between DuPont and URS Diamond, Ohfo River Water Landfill, January 2002, Corporate Remediation Sampling Proposal for the Washington Works Facility and the Letart Alliance between DuPont and URS Diamond, Proposed Groundwater Corporate Remediation Group, an Monitoring Plan for Washington Works Facility, January 2002. Remediation Group, an Alliance between DuPonI and URS Diamond, Ohio River Water Landfill, February 2002. Corporate Sampling Proposal for the Washington Works Facility and the Letart Alliance between DuPont and URS Diamond, January 2002 Surface and Dry Corporate Remediation Group, an Monitoring Report for Washington Works Facility and Local, Letart, WRuanteLraannddfilGlsr,oWunasdhwiantgetron, West Virginia, March 2002. Corporate Remediation Group, MaonnAitlolirainngceRbeeptowret efonrDWuaPsohnint gatnodn UWRoSrkDsiaFmacoilnitdy, aFnedbrLuoacray/,2L0e0t2arSt.uarfnadceDry Water and Groundwater Run Landfills, April 2002. Alliance between DuPont and URS Diamond, One-Mile Radius Survey Corporate Remediation Group, an Sampling Report and Ohio River Public Water Supply Sampling, DuPont Washington and C-Q (December 2001-February 2002). April 2002. Works an Alliance between DuPont and URS Diamond, Proposed Sampling April 2002. Corporate Remediation Group, Little Hocking Water Association Well Field, Little Hocking, Ohio, Investigation Plan for . an Alliance between DuPont and URS Diamond, C-8 Identification Letart, and and Dry Corporate Remediation Group, Work Plan, DuPont Washington Works Facility and Local, Groundwater Assessment Run Landfills. May 2002. Corporate Remediation Group, ManonAitlolirainngceRbeeptowret efonrDWuaPsohnint gatnodn UWRoSrkDsiaFmacoilnitdy, aMnadrcLhoc2a0l,02LeStaurrtf,aacned Dry Water and Groundwater Run Landfills, May 2002. an Alliance between DuPont and URS Diamond, April 2002 Surface Water and Dry Run Corporate Remediation Group, Monitoring Report for Washington Works Facility and Local, Letart, and Groundwater ^[vision of Water and Waste Management Final C.8 GiST Report Landfills, Washington Works, West Vfr-gNa, June 2002. DuPont and URS Diamond. Revised Proposed Group, an Alliance between Hocking Water Association Well Field, Washington County, CorporSaatemRpleinmgedInivaetisotnigation Plan for UWe Ohio, June 2002. May 2002 Surface Water Remedialion Group, an Alliance between DuPont and URS Diamond, Facility and Local, Letart, and Dry Run Corporate Monitoring Report for Washington Works and Groundwater Landfills, July 2002. Two-Mile Radius Survey Virginia Corporate Remediation Group, an AlliancWe absehtwinegetnonDWuPoorknst aFnadciUlitRy,SaDndiamLoocnadl ,Landfill, West and C-8 Sampling Report, DuPont (March to May 2002), August 2002. Alliance between DuPont and URS Diamond, June 2002, Surface Dry Run Landfills. Corporate Remediation Group, an Washington Works Facility and Local, Letart, and WWaastehrinMgotonnit,oWrinegstRVeiprogirnt ifao,rAugust 2002. . DuPont and URS Diamond, One-Mile Radius Survey Remediation Group, an Alliance between Ohio (March to June 2002), August 2002. Corporate Washington County. and C-8 Sampling Report, DuPont and URS Diamond, Ju/y 2002, Surface Water - Corporate Remediation Group, an Alliance between Washington Works Facility and. Local, Letart, and Dry Run Landfills, MWoansihtoinrgintgonR, eWpoersttfVorirginia, September 2002. DuPont and URS Diamond, Third Quarter 2002 . Corporate Remediation Group, an Alliance between Monitoring Report for Washington Works Facility and Local, Letart, Surface Water and Groundwater Landfills, Washington, West Virginia, October 2002. and Dry Run URS Diamond, Fourth Quarter 2002 C-8 Corporate Remediation Group, an Alliance between DuPont and Report for Washington Works Facility and Local, Letart, Groundwater Monitoring Virginia, December 2002. SanudrfaDcrey WRuanteLr aannddfills, Washington, West an Alliance between DuPont and URS Diamond, Two-Mile Radius 2002), December Survey 2002.. Corporate Remedlation Group, Report, Washington County, Ohio (June to September and C-8 Sampling URS Diamond, Revised Groundwater Corporate Remediation Group, an Alliance between DuPont Washington, and WV, January 2003. Flow Model, DuPont Washington Works, Alliance between DuPont and URS Diamond, November 2002 Surface Landfills. Corporate Remediation Group, an Washington Works Facility and Local, Letart, and Dry Run Water Monitoring Report for Washington, West Virginia, January 2003. Alliance between DuPont and URS Diamond, C-8 Data Summary Letart, and Corporate Remediation Group, an GWR-2001-019, DuPont Washington Works Facility and Local. Report,. Consent Order Dry Run Landfills, February 2003. DuPont and URS Diamond, December 2002, Surface CorporWataeteRreMmoenditiaotriionng GRreopuoprt, faonr AWlalisahnicnegbtoentwWeeonrks Facility and Local. Letart, and Dry Run Landfills, Washington, West Virginia, February 2003. an Alliance between DuPont and URS Diamond, January 2003, Surface Dry Run Landfills, Corporate Remediation Group, Report for Washington Works Facility and Local, Letart, and WWaastehrinMgotonnit,oWrinegst Virginia. March 2003. Remediation Group, an Alliance between DuPonfand URS Diamond, Sampling Investigation Corporate Division of Water and Waste Management page 50 Final C-8 GIST Report Results, Little Hocking Water Association Well Field, Washington County Ohio, April 2003. Alliance between DuPont and URS Diamond, February 2003, Surface Landfills, Corporate Remediation Group, an Washington Works Facility and Local, Letsrt, and Dry Run Water Monitoring Report for Washington, West Virginia, April 2003. DuPont Corporate Remediation Group, Letert Landfill HydrogeologicaEt valuation, DuPont Washington Works, Letart, West Virginia. July 1993. DuPont Engineering, Public Water Supply Results. West Virginia and Ohio, DuPont Washington Works, Washington, West Virginia, July 31,2002. Engineering, 3Q02 and 4Qo2 Public Water Supply Results, West Virginia and Ohio, DuPont DuPont Washington Works, Washington, WV, November 20,2002. O'Neill, Colleen M,, "C-8 Health Level Established," InDEPtb, June 2002, page 4. Tetra Tech Richardson, Tetra Tech Richardson, Inc., Inc., Monitoring Monitoring Well Well Installation Installation Program, October 1989. Program at Letart Landfill, Summary Report, August 1990. Final Ammonium PerfluorooctanoatQ (C8) West VAisrgsiensiasmDeenptaortfmTeonxticoltfyETnevairmon(mCeAnTtTal) PRreopteocrtt,ioAnu, g ust 2002. Virginia Department of Environmental Protection and the West Virginia Division of Health and Chapter 22 and Article 1, West Consent Order Issued Pursuant to Articles 5 and 12, Human Resources, Chapter 16, of the West Virginia Code, November 14,2001. l.j An air rotary'drilling rig Installing a new groundwater monitoring well at the Letart Landfill. Division of Water and Waste Management Final G-8 GIST Rep,ort APPENDIX A: Site Maps Topographic Maps Plan Views Groundwater-Top Maps Site Cross-Sections Division of Water and Waste Management FinalI C-8 GIST Report page 50 Results, Little Hocking Water Association Well Field, Washington County Ohio, April 2003. Corporate Remediation Group, an Alliance between DuPont and URS Diamond, February 2003, Surface Water Monitoring Report for Washington Works Facility and Local, Letart, and Dry Run Landfills, Washington. West Virginia, April 2003. DuPont Corporate Remediation Group, Letart Landfill Hydrogeological Evaluation, DuPont Washington Works, Letart, West Virginia, July 1993. DuPont Engineering, Public Water Supply Results, West Virginia and Ohio, DuPont Washington Works. Washington, West Virginia, July 31,2002. DuPont Engineering, 3Q02 and 4Qo2 Public Water Supply Results. West Virginia and Ohio, DuPont Washington Works, Washington, WV. November 20,2002. O'Neill, Colleen M., "08 Health Level Established," InDEPth, June 2002, page 4. Tetra Tech Richardson, Inc., Monitoring Well Installation Program, October 1989. Tetra Tech Richardson, Inc., Monitoring Well Installation Program at Letart Landfill. Summary Report, August 1990. West Virginia Department of Environmental Protection, Final Ammonium Perfluorooctanoate (C8) Assessment of Toxicity Team (CATT) Report. August 2002, West Virginia Department of Environmental Protection and the West Virginia Division of Health and Human Resources, Consent Order Issued Pursuant to Articles 5 and 12, Chapter 22 and Article 1, Chapter 16, of the West Virginia Code. November 14,2001. An air rotary drilling rig installing a new groundwater monitoring well at the Letart Landfill. Division of Water and Waste Management Final C-8 GIST Report APPENDIX A: Site Maps Topographic Maps Plan Views Groundwater-Top Maps Site Cross-Sections L Division of Water and Waste Management WASHINGTON WORKS FACILITY/ LOCAL LANDFILL Figure 1.0: Index map for the four Dupont sites. Figure 2,0; Location map for the Dry Run Landfill. Figure 1.1: Dry Run Landifli with sampling points. B-.B.----.M Figure 2.2: The Dry Run Landfill Geological Cross-Section Lines. Nuttwwt A w, Southwil A' y"''"<!!l. ;;,((,}."'. rtirn;M --, - i'ttt-ssr.sf 1. .1 ", . ^i .'-- .11.,.1 .<;.;M..;*.;t " r-r Figure 2,3: Dry Run Geological Ooss-Section A-A' < iltt aift<ntfn> Qqup ^'-^'^^^i ^-> ( 2 ft i5 si[ . " Iis il ^ --U 11-1 0 bJ (/) 51 ^ gs 5 ?S ^ 32 ~ 2. 52 cr fc w 1J U g 'A* * h 6 U> < < N Jt 3 l/l -- yi S--s 'u'*&',<,: JUO '-11 Figure 2.4: Dry Run Geological Cross-Section B-B'. Northwest A SUI , SouttOlltl C i -A 1 L L ^^r!^--^-: --.-^E^^ --[---. li.. .;';-t-'-? .- "''"''.-f^l;'---- "-I- I -TS . - B-l. MCM5 . 1 - --1 I ;- I W 1M"'9'"" ' 1" " ' ItiV'.-.--'/ i tyJ.-Vl-h'* ^ ' tsr f- Figure 2.5: Dry Ruo Geological Cross-Section A-C. North D -f. '_ . ...'S3S-. Soulh B* r,iyfl t.-, .." - '^'/;.'\<"^>'t'//''/;:.^/^;.,,.^.",'., ''^'4'Si^ r----"'"" 1 ^-~ .-. .. .----...-.. .!}- i o _J^ i*^y*i ,_-- & ffLt;. i' ^.(tcrtrfi) .,,. ^.r*-.*i- *,-:< .i"*. T (,.:; :'0li?t Mfa:l/yi --- -^ii.CHO.W ^Jl'^-111 ESS 1, f t-1 11611 >, - /:(?;(". t. SLITEH /;<(; lftW>ty\ vW S t .*. L ' 3l/0 ;i'rf;r.t' n t',i<fr&"'t^ ,-Ky< e, Ilic- f^ Figure 2.6: Dry Run Geological Cross-Section D-B' ,^&"' Figure 2.7: Dry Run Zone A Top-of-Groundwater Map* \ ' Cfrfpoft* ^M--dteH Figure 2-8: Dry Run Zone B Top-of-Groundwater Map, | oft | LTA EA oho. h pho / ve 1 A a| = Ca ne IN 0 =IREeArTN 5 BOAR PA-RESNEY "i N0)O Ne NV L}i | iLg rel> QO $4 [rpm Ma i lh Fis se oT Ay HE L sil / / Ty 4 . pr L Iz|20 xXRe Jl oF | L ;~ Faoign aNon | 5 oem |[5 2 / fn eAEle FiBtRLEeo t' Lia e | Figure 3.2: Letart Landfill and Sampling Points. Figure 3.3s Letart Landfill Geological Cro$$"Section Lines. A NORTH j^s^ SAS-aS^IWi Wfr Sftl'ilWt Si.X.1 .^UH-d. <!OhE "----./. ^ CTC-'B*''* ^f- f'.O* 'S^t'Z'Wi tWEW**'!? aWl^- (OCIREtt aSTj | ^^S11 : KSWIO'-C qeCiOQS: W" itCWWf)*;. SC*t '--10. STRUCllA SC^r I'-iC' 3,5^------- .a;1"""111"'11' iiii 11111--- 1 , "f,. ,,,,,, ....-i.. i ,. Jl HII--T ten> *,--'-wi!i<. * ^&;'s- >E-i-, ! >m- ,.,,. >.-- 1 ?^-- ys i^S^i ' 1 "' &* v;&s>- i- TyC '"1"'-- .w'&-t. IW \ A-^OMC S ;.-. :.:i...^ "r'"\ ; i ^ \ ij*ft- 4 .. - tW 1------^ - ^ ; \. ''--^ - BAO """leg ^^s^ C- ^'ONl -( .:....,. ^ ^ ^ ---.. /'3 --Y^ l ---- -. -- ^ ll/t-ZONt 6i0 -tW i " " '' i . - ' -.- ' SsO ...... . ''; f-2QNE sW -----------------:,,%, ..., .- -MB j.ECTNO ,-:- ,, -...}, S*W>1 y.^ ii ------' a.reioy*S (^,^ e LHUUl^^AH-y C. ^Lo-tV2Al- tUn :--=,/-i^&j^!iAitii rtOis r^t-.v^ m^i 'WS't; 'MI n'*ccc i'%;%" E" ' !("'& -vs ''tit W&*-" oa ==pnteit ^Bc-iogit i> jfl.1. Figure 3.5; Letart Landfill SCALE -----^ 'ro a. agate ^ Cw1frt>/t* BwdUiUort Groyp Ifc *fiW---- tlHmA ftJAl^fr, nar--rf tlW,-, CHOSS-SECHOi lelml In^ar'lt fctlO'lt WV EET--------.USa'-'"" '"'-'- la Geological Cross-Section B-Er. Noith D swm iy .-I L i i IHWC -.:., \. \ \""'- !'\. WiSWS f. : ::::^4- """-----.. . , 4 ^^'"u ~;4"^-^ ':'-:. ' v-'1 -j a y.i.is<..;.B.";\i.* t l i m m l.;;.-.i;'rL< ti.-;10i-.(!* ^V>V'l 11;; .-.tisi-'^'t ;'('' t,C.:>- ;,.'VH * Figure3.6; Letart Landfill Geological - ' W 0 ,tW?X'^ t^E^'"'-*^'* <>" -1>1> * Cross-Section D-D*. L---4-. < T--1 r--"-"~i |.,-.aas Figure 3.7: Letai-t Landfill Geological Cross-Section C-C\ Figure 3.8; Letart Landfill Zone D-E Top-of-Groundwater Map. Figure 3.9: Letart Landfill Zone F Top-of'Groundwater Map. Figure 4.0: Local Landfill Location Map. A - - riC^Ok n&- K1*-A <k. A " s-tvAt,1 *it" w*h,t Figure 4.1; Local Landfill with 40C0^^a...,.-------J------------.t,O,,Oi ' Sampling Points. BGC)" y. ..,,..,..,...,.,, ^ Figure 4.2: Local Landnil Geological Cross-Section Lines. Figure 4.4: Local Landfill Geological Cross-Section B-B\  ^ & :; A 0 ^' - ;; a .. , i * '<^ -.,, .-.L--- -'' ;- S- .1 8 ') r r r \'~ / """" I ^ ^ ? i [' ^ iB I1 !, S8 !.:. |f; s 'i A ii rt ^8 luiiinctj 51/ / s f / i .// / -'^.--tf&lQl-,-- /'r-" """' .--..i'. A.^S9 ~3 , ^I1? Illi. c' ?i:;'.,^- n: 9 'i -- .----1 r | A f/ i ,-'1"" I* : ,' / ,...- / , ' ' . ' tax.s'l ' ^ ..i,-!-- -4 i. s fif a "<J U } ^ 3:Z '--. --. ,-- -----i- --a iAU3"j-- \ -- ... 1 i <:" 1 i.. " 'KJ--, i ^.-/""" ,-r"' ^, !^ fca ;^ '\ s i i 1 a '-^ ' ^ i 1 / ', 9 ,.-... NS. 0. 3 *^ 0 ^ 0; a 0 0 - s; Vl \\ 1 0 ?. y. a < ^ 3 \ 0 ~y a i - M o 5 > 0: t**t ir *.' I--* ^ 1 g & '.^a"Sa S-. S-"a. ...tVi 5 ^>.~Q ^ ^tU PC* i ^ < r ^ '<' it o < '- *y-, ; o oil/I n vi o ?"!' ? ,' .1 S f--t.- I ', ..--..----..i.. :(; njA / 1 lir.e.r.tM / "' '&, <?' "T'" r ' b. T y '^ S-3 6 .- 7 gr-. "'- """---.,L 'V - -<.j-.^-'-"' ,.---'.i (UWM^.,.! ^M^'-^11"110^ ^ 11J & sS ~ oh". 1.1 y*(^ <" 0 ;' (1^; . ^.......^ ? ^T. 3 "R f-i; tOtiVA^l^) --("""T I* '-> "-^"""r"1 f *"' ? LL: . Figure 4.3: Local Landfill Geological Cross-Section A-A\ r--, c WE5- iK . 5 & U1 BSO'; eac' -; !.Ltt( 1> L'J<W /r\ / ! \ i ! ; \. (-' 1 S ? 1 i ^4,^, ./ 5 & "S o hy ^ ...,.,, -"^^^^^^.--.r".^-.^:-,.:-. 0 | ^W4ym^ TO . . (^ ft r--..... 3 L - <" tB 03 2 ; 5" B : ! ! W- ' 1 '^ ! i ' 8 !'. i>:na.w n'. /-,'-.-- --;,,--. ,,...-- .-- .. j,aar, ,' i \ \ -I.M'.t '18 '^,, Z-. /'' ' .'.'. ' j ' . '..'..** *--" '"' ftf'ZStWi ; . '' ,' '.'' ' ''. ^ 1 i 1Sfrt\V~ --' -- "~" e---- .;.,.- . hW- ! ~ ' ".'' ~~'- ~~ ---- --. 45.1-------------------------------------------------------"~~ 5 ;-. '.'.' ';.;..'.. ':~-'^";'7'il. "'".';.\ '.' '''\^1^^:-.'^.' "'-'''.: .''':';.. " ;-;. -.'.s'~~~ ^ :. - ,-i-.-- . >-- -- --: -- ---- -- ,.-,-- --^--.. -------^----u...=------ f ..- --'-" '.^ ""^.'--'"t "--, y-- ---- ---..--. ---- [-"" -- ------ ' '' B" '' ' - ---------- w ww ---------- .-------- ,^ a-..-- w) - - ! iK,J ^^ ^ D-ZONE ^^ ^^ . n 1 Q LEflFMC- r ----------i 1 Suti-t; i.. 1 1 jj;j Sll^ ~~' f SANDSTONE' I.'."-: ; ANO SLTStONE [--:^--~~[ r- .' I l ' -1 g I Cl.A''', vSfc'HrRCO SKAiE. *wu W:<>IH.K];U SAWiOW SWEE'"""1 """ emf-. WATeff I'EVEl WOE'ER 200? ' 1 0 ; s ^ T O ' r'E'.'rJ'.'CAi MC<jft^- WiV; .&'/ ' i.--o L^-----. ! - 1-,"' --. '*"**' 1 "------ i Cofpor.ttB HaTtoditt J58"'^- [ tw^Sffw 0 0* f Iw--ud-a- | U(J<4<. V-^ >'cj4 U^ 'U-r^i-gW. D*f*x Figure 4.6; Local Landfill Zone A Top-of-Groundwater Map. Figure 4.7; Local Landfill Zone C Top-of-Groundwater Map. Figure 5.0; Washington Works Plant Location Map. \ r^A^ A: " j .;>-, /}> t-{.' . . ',, ^;/ ' ( / / :i 7 '1 ' / " .""'"' j .^ g s-" ^Ci s, *'t' ."? . 3 " ' ' . t t 1 i ,\ ; .. >' / - ^; - ^^l ':: ^ /h i-' i!; s t i '. -C A- i"'" ^-' ::!' .^.i ( :i1'. : .'i'' , ";'.P'!i -.^' J ., :.<;^ -"'" .'..s 4-ii! ^ 1 ' ?^:.('i(.. , ;'? i i -. . ' ', y "~^~.' l^ -i ' S; ---;J.':-1in,^A, > .lill l'"1 ^ ^-^^i::'J':' s -n'il^.""5 ^ -' 'IdA;* ;i fi- ; 1^,5'.. 'it * W ' ! '\; ' r ;'' ' ( ^ ' J-r-' /-. ^ / / '-. ' / t'1^'^,.",8"'-... t! ^ - i: '- I'i '> ^^.f ^^", ''i-'^ ;! \- -\. ; . ;, - -.1 ^ \ T \ l-'" .: / '' , s ' \ s' i \ \ ij^ <; 5i Ij L 11 j| 8 si.S;' i,1i ;- ^ ?; j| 1^is .i ^ "' .. i~ . ?2' .?" i J" --- ^ - I 11^ Lig It r'- a " 1Si i ji ^ ? ~ j Q g , is 8 v --^-- i ( ; s 3 '&. I S -* 0 '/t i^ 1 t J $~. S a' ? S ^ ,l .5 o i l i U ^.1 Z li. 0 S ^ t" t H 1 ; . . "i. -,;i ;< p Figure 5.1: Washington Works Facility Sampling Points. Figure 5.2; Washington Works Facility Geological Cross-Section Lines. Figure 53: Washington Works Facility Geological Cross-Section A-A'. g(0 ii^ HiSf .4is S s "Is I l^6 ih inon t3 i^. ...! ol<? -, (0 i. Figure 5.4: Washington Works Facility Geological Cross-Section B.B'. Figure 5,5: Washington Works Facility Geological Cross-Section C-C\ ------------------------ "ior\'r S D zs7- ""Oi (TW-32) "''" c y & - i V C^ ;^ - ' VA- -:V .'I i y/'^-" --.^ .-.--< R21.VA-C- . ;;;;A';-? S-5S' a ) -22 j-2n e-?.3,^.i| 1 ' j --^*-1--^:^,'. r"/ /" ,,;?T=PF?^^U^:=as^^<l^,i-I- -- '^;$^;^ ' JlKj^.-^t.';-;^"''-""';'<;;~ / ^ - 1'fc'r i/ i ''. ..,'- , '. r - IJ^ - . ;Q-~. ' 1 ,,-- ; Y; ''^ .-^ ..=;:-.=------^::" ^,. -" ..'.'.;: '..' C^" - 1 < . -;;-^-!^' ; " ! -- i, i; ; y' ; ,' , ; ; '-' ^ ' . '**, k . ; , .:". / i : '.Sn- T,-- - ; ' ^^...,.U.. ::! = - p3 .. . ^ ;-;o - f..'-'-'^ "'"' i ;. " "T"c-a... "' .. ...T i i ---- V ' -- 'DEEP OVERBURDEN AQUIFER i. w-1! .''.L '' ,: = a -----i';".,- 1 Ni'^ QUATERNARY ALLUVIUM ^----- .,.....- -..----- ,,., i 1 'PErayilANDUNKARD-GRCHJP ', ' BEDROCK (SHALE, SiWDSTONE CONtSOJOAlED UHrT) . r'.. -i L';' . 1' ~ i ' ^' j '..;:. j; 1; -%?-?' ( ; fSi <aw - V. SS r- . iv.sc.y" ;:."j s.ii - w. S r'.' ' i~; S'3c S*'.<P><;*itV -IC.'tU! S.S a,- . ?T .--.ik-- ["'."; "> i FTC' : *21rr l.twi1 TiW S?,?! e'. i..... (or - C""--'yS'" G.'<.yntfn3tt*' fttM- 0 eil-on !4.m"""""""""""'" f-. . a-r --t^grBw> ., -,, ,, ' Ctitpfbtt llMMCbf ^ , fcrrr liiiiiin ; a^--c Bjr rrii --! 'y'".'"'--' ''." ' ;. "auj i': . ... ,." '"i.'. .! -7 -'. .......t.\.... s i ft \ " i \ : ' ; . .^ l^j g i (^ "N QQ t / ,' ' S i / / ' ' |.3-( -.'. "1\ ^ 1 l.i" . ,.. i n .l i g .4'..-1'.; | ] : i"; . - ....... . , < . -- - ..,.,,,," ,' > , - Irift i M !P- =* kJ ' 1 1 .....iiiii) g ^ " 1 1 a S 1 > w -. .- -?-I?CT o ' i Q S----1-,'----"- --" 0 i. - rti P;; > .....--"-..--..JT-JJJ ?. ' L, ;; LU ..^ g-ffi.4..L .^.--.L- .1^.. > ^R-.'-.. i ' ' 1 " - " ' ,-(- ;"i *.,--,. . ^, \ '-'%. ? '\ , "--, ; ,- >-^-'\:-^^A ' .. --J "v'Y\ \ \\ , ',,, \ V'.,'.^-' -.' \ \ \ ; (j ! : j , .;..-,-., .-.,..--.,. <: '.' t:* i> -. .-. i;: t-i A^- . .' , ' '' 1 S 1- . . . . . . . . i - i J i UJ /; c ^n '.J f^ I/? .' i'- 1 VI t" i ':. !"- ^>.; ^ 1.:.i il,l. ' ^ ^ p 7i 11.1 $! ^ ^ I a !l " ; 5 Dp ' " fl -s -y M '.1 fl "*.? ^ 1: /I 0. s" ,nis ^.w 3 il 't A i - !;: . & "I i l " (t 5 8 a n 8 J; ,^ JL i Figure 5.7: Washington Works Facility Geological Cross-Section E-E'. ; ' . L..L -I... .1 4---- ; l"- a t; W-: .'>' ____ .,,_ ..^. \ \, s h ^-I-A . - . ; '-:^' b ;7 ;u', - - S^l 3 q-T > 3 : .; '1: - t ? -L- -f z-^--^ l . f/:. ^ ' ' ^.,'wu- ' '' : .'^ I1- U ^u ,3 n:J * ?. <*;. "t 5 i. ? > 2 " ;--r--i -y H -T, - u Figure 5,8: Washington Works Facility Geological Cross-Section F-F\ ^>.. [ ; ,- t r r 1. I- ...,, 1 [ c rG ' ;,,... -:--. -- i- ''-** f ' "^^'T" r . - . * i "'-?'-) y .;...." -'"~L'--"'" 1h :6iill.-.. "'" ";..:i < ,,- ^>--- ---.. i^ .*<. - . i14. *"JMB.J'T'"-""" ""~1 i G - .:' ' ';:,,.. .... ^ . .' .: v^^, .;;it ! ' .T1 i?l r. .!i .; /' .<-'^ m^y . 5 \ -i-i i i- ff- 1 /'"B 1 ^ ;., ';;!' i... < 0 KfV. ;< t T '^M^f -;"<'^i j,^"t;-^-^,.^"^^^'0J..-a...;^/^^''^e!.,'6:3^;^-!^^!9[|:^^^ -;| ir----^'y ;.". '; ' 1 ( , j :j' X--, . ,;".. .^-.^ ";ffl' ''" ""'i!!- " / ,-? .'A ''h / I " '0' : .;; '-: i-. .' s -. "' . ':;' ,-i. {. i '; - W '^' ' '" /!.. :^:?:;-&:^ '- ^ ^cy'.<?>;:<:,.,^ i >-.- -., u' .. ^ "'..;> . 'a:'''?: "''" ff" o. . - '. ^ '^f^: "'. .-';'" ':;'"; oA , ( .'"'.i''.i i ''' :;.;.: ' -' ' ; ;<fltBSir c"(pcxalB Rtim(l*Uen --t^ < i^)^,^ ^ >->J MJ. ..'&!' rf,A,-v4 -0 BroUp t." . ... -. ------,,.. s1 : t;' ^ .^' E. ..l>; .*' .;;, /;:' ---;: 'l-"""~'irirfr " y/a;----- ^''-'-1. i - .^ j Pigwre 5.9: Washington Works Facility Geological Cross-Section G-G'. Figure 5.10: Washington Works Facility Top-of-Groundwater Map. Final C-g GIST Report APPENDIX B: Groundwater data (both graphs and tables) Division of Water and Waste Management DRY RUN LANDFILL SURFACE WATER ^<^>^<^ ^ ^^^c^^^o^r^^<^<^l't^^c^^c^/ ^-^c/ ^^^c^<^^^o0^^^^^<^/ Date OutetOOl -it~OufetOD3 OuUet004 ---Boundary ^-Stream^l --Stream#2 -^-Leachate --Un DRY RUN LANDFILL ZONE A GROUNDWATER ^ <' ^^ ^^ ^0 ^<> ^^ ^^ ^ ^ ^ ^ ^ ^ ^ r ^ ^ ^J^ ^ ^ ^^ ^ Date -DRNtW-12-*-DRNW-13 DRMW-15-^-Limi' t--. r DRY RUN LANDFILL GROUNDWATERZONE B J^(J i,r..,-,i,i----)----i--.^--..iy-..-^p..^.i..-^^CT..^jJjK.n...^^.np>.-imH^ ^ ^ ^ ^ ^> ^ ^ ^ ^ .^ ^ ^ ^ .^ ^ ^ ^.^ ^ ^ ^ <^ nDiaateo ^J^ ^^' .59' ^ ^ ^ DRMW-6 --DRMW-6A -DRMW-17B----DRMW-18B DRI(/JW-12A -<--DRMW-12B -^-DRMW-13A --DRMW-1 DRMW-19B DRNW-20B DRMW-21A -Limit "iu Pont de Nemours and Company ry Run Landfill Wood County C8 water data Units are ufl/1 A zero equals a Non Detect concentration A yellow-colored concentration is above the WV-DEP limit Groundwater monitoring well MW-21B is actually a "Zone C" well GroundwaterZone A- DRMW-13 DRMW-15 Limit Date DRMW-12 150 May-91 Apr-93 150 Jul-94 150 Jun-98 150 Apr-96 0 160 Jul-97 0 7 150 May-98 0 9.2 150 Jun-98 150 Jul-99 0.134 3.6 0.263 150 Jul-00 0.16 9.8 0.763 150 Dec-01 0.086 9.86 4.94 150 Jan-02 0.116 16.5 4.35 150 Feb-02 0.11 11.5 3.65 150 Mar-02 0.0929 12.6 4.91 150 May-02 0.0817 16.9 5 150 Sep-02 0.0626 13.1 3.99 150 Oct-02 0.109 20.9 4.92 150 Mar-03 0.101 15 4.64 150 GroundwatcrZone B" Date DRMW-6 May-91 0 Apr-93 0.4 Jul-94 0.5 "Jun-95 0.6 Apr-96 Jul-97 0.97 1 May-98 Jun-98 Jul-99 Jul-00 Dec-01 Jan-02 Feb.02 . Mar-02 May-02 Sep-02 Oct-02 Mar-03 DRMW-6A 0.19 0.36 0.27 0.096 0.212 1.04 0.824 0.822 0.843 1.24 0.785 1.13 0.727 DRMW-12A 0 0 0 0.081 0.128 0.158 0.168 0.125 0.0785 0.0832 0.088 0.181 0.059 DRMW-12B DRMW-13A DRMW-14 11 0 15 0 8.7 0 0 5.4 0 0.215 0.085 0 00 0 0.258 0.052 0.07 9.9 6.4 5,97 43.73 2.31 5.14 6.66 1.5 2.5 0.115 0 0 0 0 0 0 0 0 DRMW-16B 0 0 Date . )RMW'17B DRMW-18B DRMW-19B DRMW'ZOB DRMW-21A Limit May-91 150 Apr-93 150 Jul-94 1SO Jun-95 150 Apr-96 Jul-97 May-98 Jun-98 Jui-99 Jul-00 Dec-01 Jan-02 Feb-02 Mar-02 May-02 SOecpt--0022 0.155 0 0 0 Mar-03 150 150 150 150 150 150 150 150 150 150 150 150 0 0.27 150 0 0.138 150 Groundwater Zone C-- Oate DRMW-21B Limit May-91 150 Apr-93 150 Jul-94 150 Jun-95 15" Apr-96 m Jul-97 150 May-98 160 Jun-98 ^ Jul-99 '150 Jul-00 '150 Dec-01 ^0 Jan-02 150 Feb-02 ''50 1 Mar-02 1SO May-02 Sep-02 Oct-02 150 ISO 0 150 Mar-03 0 150 Wet surface Water- [We 001 Outlet 003 Apr-96 86 Outlet 004 Property Boundary Stream^ 9.9 Stream #2 Dry Run LeacAate Pond Underdram Limit ^ I- ^SfS'o0-0?22 ., f Ju'-97 May-98 17 1 1 44-86 5560 . - - Jul-98 f\-8080 Dec-99 68 3W 9 0".-5^4 Q87' 34 - OctOO 315 10-3 3.99 -758 1.19 27-6 20.5 27A 109 35.4 416 11.1 0.893 42.4 398 29.3 43:9 3.81 0.86 24.3 256 37.1 Mar-02 71.6 6.77 158 22.8 1.06 66.6 334 66.7 j Apr-02 41 20.1 6.69 0.932 28.9 237 33.4 l- May.02 30.9 9.41 1-63 51 150 67.4 j Jun-02 . Jul-02 25.3 0.7 1-- Aug-02 , %(! 81.7 Nov-02 64.6 Dec-02 56.9 3.8 1.63 29.2 704 38.8 ^ ^ ''SO ISO W 150 1]c5n0 SO 50 50 50 150 J50 150 IgQ 150 150 150 150 150 D,r^ 0^0^0^003 S^.2 Jan-03. Feb-03. 88-4 69 0^004 ^ Boun^ Streak 150 61.1 99.7 99.7 150 Leao^e Unde^ Umit 10000.0 1000.0 E--; r LeTART LANDFILL GROUNDWATER ZONE F LMW-2A -*-LMW-5B Date UVIW-g -fe-LOT-9 --LMW-10 -I-IMW-H ----LMW-12 "--LMW-138 ---- i--' r LeTART LANDFILL GROUNDWATER ZONE D-E - LMW>3A --LMW4 Date LMW-5A -^- LMW-13A -^- LMW-14A -- Umit fc LeTART GROUNDWATER ZONE C -.rw.-.".-..f. ^i].efe'^aJ.^rf .'j.-^.-^i^T': i-',.'".'_-^"^ g-'^-'yj'i.J'i :-^--j.fsg-.~j,: ^".s-^.s. &-;.'; '"^^:3ti^j ^tf'-'v.i'.^'A "j^-j^j^-.-rt^i.'gji'^.-". 't.^ ^ i^ ^ ^^8B^iil%^ . ^^j^- S^^ 1;^^ iis^l g ^ ^ ^ ^ ^ g^'^^^y^^^^^^ Fl^^lg^lS^^g^sgag^^^is^ ^^^l5i11^^3lS^^j^;^gl fi^^sB^S"^^i'^%^^%i!^^:^isa^ ^B^^^^^S^^ii^^^^i^^^S ^? ,_,.,,_..,,_. .,..,3 feljgi^ ggpR'^1 fe%S W . , ^ _ j ' , " ^^^ _j ^fci^^^ ^|gl^8 ^^l^^ ^^^^^jil^i^^S;^^ I^S^I ;5JfeggS g I ^ ^si ^^ :^^ ^SS ^"' l^^ft ^lT^sf^e.i'jyi.3'ai't'Kg?^s^!^s^!^al ^rsa^sS^fe|^ ^^^ iSlll paa.^y.^^.-^.y^Mg,-.,-. ..y.,-,-,.^j^.-;...^..-;---,- -^ ^ ,.,, _ :^:: ^i^ ^^ a^:^ ^^N^Sa^ S.^I^N^^%S^ ^S? ^a^^ '^sS^|K -LMW-3 -i^Limit 100000 n LeTART LANDFILL GROUNDWATER ZONE A -E.1WV-1 --LMW-7 LMW-8 -'--Limit w LeTART LANDFILL SURFACE WATER \ "^ MeTro2~-- (Met 003 ~ Date SW RunoF'^'"US'^S^am -^"BmterRun ---Cap^uno Du Pont tie Nemours and Company LeTart La ncltill 'ason County C8 water data Unite are p9/l AA zyeerloloewq-cuoallosraedNcoonncDeenttercatticoonnIcseantcroatniocenntration above the WV-DEP's level Groundwater data" F-Zone wells" LMW-2A MW'5B LWM-G LAW-9 LWM-10 Dt/QalfOe ~ 50 340 25 Mar-91 Nov-91 63 380 24 Oct-92 0.2 Mar-94 260 1200 Mar-94 530 Sep-94 270 480 Apr-96 460 LWM-11 LMW-12 Jul-97 i.- May-88 Jul-99 | r Oct-99 Jan-00 Apr-00 |, Jul-00 Oct-00 1 Jan-01 Jul-01 460 990 350 370 453 306 275 24$ 423 242 445 1750 1030 1020 1100 900 1190 615 592 30 9.4 15.8 0,848 0.134 0.128 ' i l l,s^ Dec-01 Jan-02 ly Feb-02 1 Mar-02 May-02 Sep-02 Oct-02 f Mar-03 830 1880 740 1890 714 1460 717 1810 922 1720 676 1460 931 22SO 676. 1470 18.1 14.9 14.8 20.7 10.5 15.1 11.6 0.875 0.617 0.631 0.715 0,479 0.907 0.625 0.133 0.126 0.136 0,298 0.159 0.112 0.119 0,069 0.058 0.121 0.12 LMW-13B LMW-14B Umit. 0.0956 0.149 105 70.4 D-E Zone v vells- Date LMW-3A LMW-4 LMW-5A LMW-13A LMW-14A Limn i j Mar-91 380 690 1.6 150 ~ Nov-91 350 830 0.8 150 1Iw1U0 JJaunl--0909 60.3 172 150 1 Apr-00 272 150 Dec-01 100 1580 94.4 160 Jan-02 98.6 3060 99.3 150 I Feb-02 101 2250 82.2 1SO lvlar-02 132 2620 93.6 14 5ff0\ May-02 134 1690 87.6 150 | Sep-02 1410 150 1- Oct-02 204 2840 112 510 974 150 Mar-03 144 1520 144 498 150 I C-Zone wens-. Date IMW-3 Limit Mar-91 390 150 Nov-91 1000 150 Dec-01 1520 150 Jan-02 1700 150 Feb-02 1920 150 Mar-02 1760 150 May-02 2270 150 S*sp-ur\-^'- 150 Oct-02 0 150 Mar-03 150 A-Zone v/e Is.. Date LMW-1 Mar-9-1 60 Nov-91 68 Apr-96 Jul-97 1700 5100 May-98 Jul-99 24000 6020 Oct-99 12600 Jan-00 17400 Apr-00 13600 Jul-00 8990 |' Oct-00 10600 \ Jan-01 9190 Jul-01 6100 Dec-01 24600 Jan-02 29400 Feb-02 18400 Mar-02 20600 May-02 30500 Sep-02 23000 Oct-02 25900 ,B^,ifcl Mar-03 25000 !Uy Surface water- Iwwv Date Apr-96 002 Jul-97 Jul-99 | t Oct-99 3240 Jan-00 920 Apr-00 1900 j Jul-oo , Jul-01 1350 159 - Nov-01 53.2 Dec-01 36.1 Jan-02 Feb-02 50.1 355 Mar-02 131 , I Apr-02 May-02 1 Jun-02 443 1630 Jul-02 1410 | Aug-02 [ Sep-02 Oct-02 2050 4.52 645 j , Nov-02 Dec-02 *" Jan-03 Feb-03 639 1170 Mar-03 LMW-7 0.1 15 53 260 78.3 339 219 211 158 231 249 242 334 496 180 324 567 197 300 218 003 0.39 0.148 0.198 0.0653 0.282 0.17 LMW-9 Limit 14 ueUn 280 150 2200 160 2000 150 2700 150 1790 150 3260 150 2100 150 2180 150 2160 150 2300 150 2650 150 1120 150 3240 150 3930 150 2230 150 3520 150 4020 150 3100 150 3480 160 1720 150 StomwaterRoute 33 Runoff Stream 1.8 2 2.23 0.573 2.01 1.9 3.92 1.26 0.845 1.57 50.9 2.24 2.83 2.27 Brinker Run 0.0612 0.247 Cap Runoff 119 279 371 102 65.1 415 Oate 002 003 SW Runoff 33 Stream Brinker RurCap RunoffLimit LOCAL LANDFILL SURFACE WATER ^ ^ ^/'^ ^ ^ ^ ^ ^^ ^ ^^ ^ </ Cf ^ ^ <^ ^ ^ ^^ ^^ ^ ^ ^ ^ ^ ^ ^<^ ^ Q6- ^ ^ ^ Date -Outfall 004 --New004 Outfall 005 --'-New 005 -^-Outlet 101 --Outlet LM LOCAL LANDFILL GROUNDWATER ZONE A - LLMW-4 --ILMW-6 LLMW-9 -^- LLMW-10 -*- Umit ^i- LOCAL LANDFILL GROUNDWATER ZONE B "''."..i.":'' ^.-'^^''S .' 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' :-'' " '.' . <^ ^ c^' ^ ^ .5^ ^.<^ ^ ,^ 5^ </ ^ -/ ^ ^^T< ^ ^ < ^ ^ ^ ,y / ^ ^ <& Date LLMW-12B--limit LOCAL LANDFILL GROUNDWATER ZONE C ";'f!,'<^ ^ ^ ^m ^,A-J -----; ^.j.dif. ^ ^ W& '!9'>''S' ll'.itJa^w ^ !?>S^ ^ ^S &^ ^"i' s ^ ^ m m tWiSt.:' ^ fe?.iU e&s& a^ sm 1;^ ^ .,';t;5|S?^gi^ ^WB ?.(',!? SP^i RS%.? ?sasis ^ ---- r; .ifc"^ ^ 1 ite-a t-fe^ ym.W a^ ft'3^ m NS1 1^ w^ a^ ^1 ^ a 1 ..^ -.1 TNte- c--- ^s- "^VWi4^-; ,".,...; ^- ^"T.il s"^.'' - Si^y ." '' -' ':' : ^-, '4'^ft '' 'Sj'f\--' ^\l.ff;;:,^ ','-'"-';^ s^ S^i ^sp wsn F-%; ^'"^ ;R-:-":^ ^ K^P^ ^-Tt^'.' ^;ft!'; ?;;;^;U ':.;',l'i; .'&'' fe^ ^^ m ^ ^'i'j ;sr, ''/; ^ ^ [';.."' '^ (..y.:y 8^ ^N iiS^/i ^^^ ^'.f''''!?^ ^^-^ f^,^ ^.j^1 ''" -'^^ (.a.::':^- i.'. / ^ -:' '.1 ^/.'?.: ^ ^ '-^.^ -^ ^S :"5 ----" ' '"'.'" i*-^ l6-^ s ^ .''"' <-'.-; - ^ '""^ ...'.' -', . 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'*" ;-. ., ,' .': ;-;;- ^^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ J^ </ ^ ^ ^ ^ ^' c^ Date |-^- LLMW-11A -- LLMW-13B LLMW-14B -J-- Limit LOCAL LANDFILL GROUNDWATERZONE D 1000 T [----ir"1"" 'r ^g 9 ^^ ^a; -i^ ^"^ '^.Naa - ^ - ^ ',?;, ";s af.-^ :.'*E'gc ':'l:';' ^^ .^3 ^'K :s 'sy.^.' ^ ^ a^ ^^ s^ ^1 S^ ^a '.K^ IS 1^ ilSI^ 111s1 ^ ^^ 's^^ sa^a^s ^te ^aN^i 1%^^ ^^ 1% ^ fl^ ^ g^I y:'^5 ^s ^^ ^I| A;;?"it ^ i-ii ^ - -^ ^^ 1 ^N1 m ^f?"!! a ^S ^ P|%-5^pN 13- -i--^ ; I"!'* ^^..-<;} ^^ i"^ S^ ^rt loo '^T-'S >";-,^,; : ^" ;%'s f^nSf^ ^-&'^;.-; ft''A V^s; S:"^.^ ;\<.v.% ^^ M Vi-7'*-'^ .-^^ ?i.<^'3 i'-^." :""';;','* ;.'^- ;.-.;;-;. i'S: y':-'"f 4i5^ ^-s-'-^;/. -.,- ^"^ 's's^ ^"iSt.1 g'sS'p gj'':;gs ";,-'':< 'A'"' '3^'; S^t %' r'1,^ s-"-?'??'"?;?;?:?.:' l^'^i 'i?^ vi^f: W-K!' i-srir-:'- t5,'A'?c ^ri?,t.-&|i;ttr:-'^-'' !.^'^t-'l^.;.". >tt.: ^%a; tepi f^y's-. 'i .''y i* S^-?; ;.;y.;...v^^^F*i;;W,;'7"i; .^-'.;; -. '';-'^ '.i-'.'.l' y;^:. %^< ^' "?f^-r'"S%K', ."' 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Date --LLMW-11B --Limit pu Font tie Nemours and Company Local Landfill Wood County C8 water data Units are |jg/l A zero equals a Non Detect concentration A yellow-colored concentration is a concentration above the WV-DEP limit Gro undwater Zone A- Date LLMW-4- LLMW-6 LLWM-9 LLMW-10 Limit Apr-96 39 15 0 150 May-98 26 9 0 0.22 150 May-09 16.2 1.32 0 0.15 150 May-00 10 1.42 0.039 150 May-01 1.4 3 0 150 Dec-01 54,6 11.9 0,046 0.133 150 Jan-02 58.4 " 12.2 0 0.146 150 Feb-02 50.2 10.1 0.14 1.12 150 Mar-02 47.2 11,5 0 0.698 150 May-02 55.7 18.6 0 0.56 150 Sep-02 63.5 13.7 0 0.357 150 Oct-02 79.6 19.9 0.056& 0.395 150 Mar-03 52.4 16,1 0 0.318 150 Groundwater Zone B-- Date LLMW-12B Limit Apr-96 150 May-98 150 May-99 150 May-00 150 IVlay-01 150 Dec-01 150 Jan-02 150 Feb-02 150 Mar-02 150 May-02 150 Sep-02 150 Oct-02 0.0658 150 Mlar-03 0 150 GroumdwaterZone C- Date LLMW-11A LLMW-13B LLMW-14B Limit Apr-96 150 May-98 150 May-99 150 May-00 150 May-01 150 Dec-01 150 Jan-02 150 Feb-02 150 Mar-02 150 May-02 150 Sep-02 150 Oct-02 2.22 6.61 0,488 150 Mar-03 2.05 6.38 0.317 150 GroundwaterZone D- Dafe Apr-96 ^lay-98 r^lay-99 LLMW-11B Limit IVay-00 (Vlay-01 Dec-01 Jan-02 Feb-02 lMar-02 May-02 Sep-02 Oct-02 0 Mar-03 0 150 150 150 150 150 150 150 150 150 150 .150 150 150 Surface Water- Date Outfall 004 New 004 Feb-94 11 - Apr-96 13 May-97 13 Jun-98 12 Jun-99 3.06 . Dec-99 7.1 Sep-00 4.73 Dec-01 Jan-02 11,4 Feb-02 10.9 Mar-02 1,51 14.6 Apr-02 15 14.5 May-02 Jun-02 10 9.29 Jul-02 11.6 11.2 Aug-02 Sep-02 Oct-02 Nov-02 Dec-02 12.5 10.7 Jan-03 Feb-03 Mar-03 14.7 15.9 Date Outfall 004 N@w 004 Outfall 005 35 39 41 New 005 39 6.8 34 13.3 51.4 46 39 40.9 16 34,3 27.3 32.1 " 38.1 9.51 44.9 Outfall 005 New 005 Outlet 101 Outlet LM1 54 15 12 - 82.4 81.4 63.1 3$.4 48.2 40 38 63 70.3 115 78.6 76.7 120 49.5 81.7 72.3 ' 43.6 45.4 Outlet 101 Outlet LM1 Limit Limit 150 150 150 150 150 150 150 150 150 150 150 150 150 150 150 150 150 160 150 150 150 150 150 1000000.0 100000.0 10000.0 WASHINGTON WORKS GROUNDWATER -AE11-NW01 -K16-PW01 --:----Q04-MW02 --,<>--N04-MW03 -B-AM07-PW01 ----L04-PW01 -*~R04-MW02 Y14-MW02 A008-PW01 ---- N04-MW01 -.9--V05-PW01 -A-Limit Date --<-AX13-PW01 N13-IWV01 Y14-MW01 ^t&-D08-MW01 -< P04-MW-2 ----West Well Field -- -- WASHINGTON WORKS SURFACE WATER --Outlet 001 --Outfall 002 Date . Outlet003 -^Outfall 005 -^-Outlet 007 --Outlet 10 Du Font d Nemours and Company Washing'ton Works Wood County C8 water data Units are pg/1 A zero equals a Non Detect concentration is concentration above the WV-DEP limit A yellow-colored concentration a f I L [ | I 1. ^^ '^SIS1' I / | *-- 1- | J 1. I r Groundwater- Date Aei1-MW01 Apr-96 Jun-97 Jun-98 AM07-PW01 A009-PW01 AX13-PW01 0.48 0.52 0.79 0.55 0.4 1 D08-MWO-1 E13-MW01 K16-PW01 L04-PW01 N04-MW01 2 0,48 7.9 Nov-98 Feb-99 May-99 Aug-00 Nov-00 0.41 1.9 0.69 0.082 0.578 0.307 0.071 0.167 0".-2"4 A0.-4I 0.59 0.882 16.2 7.5 5.89 13.8 Jan'01 389 Apr-01 ' 0u.2^u0<2; Jul 01 jan.o2 Feb.02 Mar-02 Apr-02 May-02 Sep-02 Oct-02 Mar-03 0.131 0.355 0.582 2,11 10.5 30.9 689 1.2 1.45 0.129 0.439 1.03 1.22 1.27 0.262 2.32 1.62 12 17.2 23.5 40.9 2.82 1.22 0,171 0.169 0.568 0.497 1.42 0.424 2.44 13.2 . 16.1 12,4 15.1 125 1.92 0.247 0.335 0.499 0.42 0.911 0.834 0.721 0.551 0.117 0.126 2.47 2.39 3.43 9.71 16.2 3.06 14.03 174 0.269 0.415 1.37 0 0.308 1.07 3.72 3.15 8.93 19.8 Date N13-MW01 P04-MW-2 P08-MW-01 Q04-MW02 R04-MW02 V05-PW01 Y14-MW01 West Well Field Apr-96 Jun-97 Jun-98 Nov-98 peb-99 0 29.6 8300 13600 36' 660 1300 0.66 12 994 9420 12.4 4.95 May-99 Aug-00 Nov-00 Jan-01 Apr-01 ' Jul-01 Jan-02 Feb-02 Mar-02 Apr-02 May-02 Sep.02 Oct-02 Mar-03 57.8 12600 23600 26800 32300 36500 42400 34400 46600 36900 43.4 20.7 120 1480 1590 2070 1210 1480 32.2 7720 666 13800 47500 43600 54400 56300 68100 66500 84100 322000 13-7 5.48 11.4 29 25.1 40.9 37.6 35.8 34.8 51,2 42.5 12.7 10.9 15.5 13.9 15.3 18.4 18.2 15.7 1.58 2.31 2.31 1.58 7.72 6.69 7.09 6.41 10.3 7.2 I Dale /'\J06^IW-02 N04-MW03 Y14-MW-02 Limit Apr-96 150 Jun-97 150 Jun-98 ^g0 Nov-98 150 Feb-99 150 L> May-99 150 Aug-00 150 , Nov.OO 160 Final C.8 GIST Report APPENDIX C: Consent Order No.GW-2001-019 Division of Water and Waste Management CONSENT ORDER ISSUED PURSUANT TO ARTICLES 5 and 12, CHAPTER 22 AND ARTICLE 1, CHAPTER 16 OF THE WEST VIRGINIA CODE. TO: E. I. DU FONT DE NEMOURS AND COMPANY DATE: November 14,2001 West Virginia Department of Environmental Protection West Virginia Department of Health and Human Resources Order No. GWR-2001-019 This CONSENT ORDER is issued by the Director of the Division of "Water Resources and Director of the Division of Air Quality, West Virginia Department of Environmental Protection, and the Commissioner of the Bureau for Public Health, West Virginia Department of Health and Human Resources, pursuant to the authority set forth in more detail below. I. INTRODUCTION OF PARTIES. This Consent Order is entered into by and between the West Virginia Department of Bnvironmental Protection [WVDEP], the West Virginia Department of Health and Human Resources - Bureau for Public Health [WVDHHR-BPH], and E. I. du Font de Nemours and Company [DuPont][collectively referred to as the "Parties"]. II. PURPOSE OF CONSENT ORDER. This Consent Order sets forth a series of tasks to be performed by the Parties in order to determine whether there has been any impact on human health and the environment as a result of releases of ammonium perfluorooctanoate [C8], CAS Number 3825-26-1, to the environment from DuPont operations. C8 is a material used by DuPont in its fluoroproducts manufacturing process at its Washington Works facility located at Washington, Wood County, West Virginia. C8 is not identified as a hazardous substance, hazardous waste or otherwise specifically regulated iinder West Virginia or federal statute or regulation. This Consent Order has been negotiated in good faith and the actions undertaken by DuPont pursuant to this Consent Order do not constitute an admission of any liability on its part. DuPont retains the right to controvert in any other proceedings, other than proceedings to implement or enforce this Consent Order, the validity of the findings of fact and conclusions of law set forth herein. DuPont agrees to comply with and be bound by the terms of this Consent Order and further agrees in any proceeding to implement or enforce this Consent Order that it will not contest the validity of this Consent Order or the jurisdiction ofWVDEP and WVDHHRBPH to issue it. III. DEFINITIONS. identified below are used in the Consent Order or in any exhibit or Whenever the terms the following definitions shall apply: attachment hereto, 1. "The Agencies" shDalelpmaertamnetnhteoDfeEpnavritrmoennmt eonftHaleParltohteacntidonH,uimncalnudRiensgotuhreces, Bureau for Public Health and the . Divisions of Air Quality and Water Resources. "C8" shall mean the chemical compound ammonium perfluorooctanoate. 2. "Detection Limit" means the lowest analytical level that can be reliably achieved within 3. specified limits of precision and accuracy under routine laboratory conditions for a normal operation of a specified matrix.'It is based on quantitation, precision and accuracy under compliance-monitoringprogram to have a sufficient laboratory and the practical need in a number of laboratories available to conduct the analyses. "Effective Date" shall mean the date set forth in Section XVII of this Consent 4. Order. "EPA" shall mean the United States Environmental Protection Agency. 5. D "Force Majeure" shall mean conditions or circumstances beyond the reasonable control 6. ofDuPont which could not have been overcome by due diligence and agencies, shall include, administrative or .J without limitation, acts of God, action or inaction of governmental or disputes (provided, however, DuPont judicial tribunals or other third parties, or strikes or labor demands), which prevent or delay DuPont from shall not be required to concede to any labor complying with the work plan. Monitoring Well" shall mean any cased excavation or opening into 7. "Groundwater by digging, boring, drilling, driving, jetting, or other methods for the purpose of the ground made biological, or radiological properties ofgroundwater. The determining the physical, chemical, includes piezometers and observation wells, which are installed for term "monitoring well" listed but does not include wells whose primary purpose is to above, purposes other than those provide a supply of potable water. 8. "Groundwater Well" or "Well" shall mean any drilled or excavated agricultural groundwater and shall collection system that supplies water for public, private, industthriiasl, or use applies only to wells include drinking water wells. As used in this Consent Order, term located in West Virginia. "Reimbursable Costs" shall mean costs attributable (on an hourly basis) to the 9. in the negotiation and implementation of this Consent Order, the work of Dee Ann Staats, Ph.D. participants on the C8 Assessment ofToxicity Team, as described costs attributable C to any other this Consent Order, who are serving in that position as contractors to in Attachment to by WVDEP in connection with the public meetings described in WVDEP, costs incurred attributable to any contractor retained at the direction of the A-ttachment C, and costs Investigation Steering Team (GIST). Groundwater "Washington Works" shall mean the manufacturing facility owned by DuPont and located 1in0.Washington, Wood County, West Virginia, as depictedon Exhibit 1 to this Consent Order. "The Facilities" shall mean the Washington Works and the Local Landfill, 11. Landfill, depicted on Exhibit 2, and the Dry Run Landfill, " depicted on Exhibit 1, the Letart depicted on Exhibit 3. Dose" or "RfD" shall mean an estimate (with uncertainty spanning 12. perhaps an "Reference order of magnitude or greater) of a daily exposure level for the human population, appreciable risk of deleterious including sensitive subpopulationsthat is likely to be without an specifically developed to be protective for long-term effects during a lifetime. Chronic RfDs are exposure to a compound. "Screening Level" shall mean the concentration in a specific media such as during air, 13. without an appreciable risk of deleterious effects a water, or soil, that is likely to be lifetime in the human population. IV. WAIVER OF RIGHTS. DuPont waives any and all rights it may have to appeal or challenge the validity or jurisdiction of the Agencies to requirements of this Consent Order, and shall not challenge the issue thTishCisonCsoennsteOntrdOerrd. er applies to and is binding upon the Parties, and their successors and assigns. V. FINDINGS OF FACT. C8 is a chemical substance which has no established state or federal effluent or 1. emission standards. C8 is a perfluorinatedsurfactant manufactured by the 3M Company and others. 2. Since the early 1950's C8 has been used by DuPont in its fluoropolynier-related manufacturing processes at its Washington Works facility, located in Wood County, West Virginia. 3. Residues containing C8 from fluoropolymer manufacturing processes at Washington Works are or have been released to the air, discharged to the Ohio River, disposed of at the Facilities, and otherwise shipped off-site for destruction and/or disposal. DuPont also captures for recycle a significant portion of used C8. 4. No permits issued to DuPont authorizing releases of pollutants to the environment contain specific limitations on the amount ofC8 that may be released to the environment. However, C8 releases are addressed more generally in WVDEP Division of Air Quality permits as paniculate matter, PM]O (particulate matter with an aerodynamic diameter less than or equal to 10 microns), or as a volatile organic compound. 5. Since as early as 1990, DuPont has performed regular, voluntary water sampling to detect the presence and level ofC8 in and around certain of its Facilities in West Virginia and has reported the results of this sampling to various government agencies. Currently, DuPont also samples and reports C8 concentrations in water as required by permits issued by WVDEP and EPA. 6. As a result ofDuPont's sampling, C8 has been detected in varying concentrations in and around certain of its Facilities in West Virginia, including private drinking water wells and public water supplies. 7. Analyses of water samples have reported levels ofC8 in the Lubeck Public Service District ("LPSD") drinking water supply. 8. DuPont, by and through its use of C8 in the fluoropolymer manufacturing process, is the likely source of C8 presence in and around certain of its Facilities in West Virginia. 9. Along with environmental sampling for C8, DuPont has performed and participated in multiple studies examining the potential effects ofC8 exposure on human health and the environment. 10. Studies performed by DuPont and 3M have determined that C8 in sufficient doses, i.e., considering both amount and duration of exposure, is toxic to animals through ingestion, inhalation and dermal contact. Studies have also found that C8 is persistent in humans and the environment. 11. Although DuPont has collected a large amount of data on the presence of C8 in the environment, the Agencies believe that additional information will assist them in delineating the extent and concentrations of C8 in the environment at or near the Facilities. Available data collected by DuPont indicates that C8 is present in the surface and groundwater at the Letart and Dry Run Landfills and at or near the Washington Works facility, 12. WVDEP and WVDHHR-BPH have determined that it is desirable to ascertain the source of drinking water for persons potentially exposed to C8 in groundwater or surface waters in the area of the Facilities. 13. EPA, WVDEP, and WVDHHR-BPH, in consultation and cooperation with one another, have requested, and DuPont has submitted, information and documents relating to the detection and presence ofC8 in and around the Facilities and documents with respect to the human health studies being performed related to C8 exposure. 14. Based upon information submitted by DuPont and reviewed to date by EPA, WVDEP, and WVDHHR-BgrPouHn,dthaendAgseunrfcaicees wbeatlieervsentohwat caodndtiatiionninagl dCa8tahwavoeualdcaosmsipslteitne their eevxaplousautiroenpaotfhwwhaeythtoerhtuhme ans and whether persons in and around the Facilities are at risk of adverse health effects from C8 exposure. 15. There have been no independent governmental or non-industrial studies performed on the human health effects ofC8 exposure for the purpose of establishing an exposure standard for C8 applicable to the general public. 16. The Agencies have concluded that full site and health assessments are necessary to ascertain the extent and level ofC8 concentrations in the environment and to assist them in determining whether C8 presents any possible danger to the public. DuPont has agreed to participate and assist in this effort. 17. The fluoropolymers industry has committed to EPA to reduce total actual C8 emissions for either the year 1999 or the year 2000 by 50 percent within three to five years of each company's commitment date. DuPont committed to this goal in 2000. 18. DuPont installed, in March 2001, a filter and carbon treatment system at its Washington Works facility that is demonstrating removal efficiency of 90-95% of the C8 in its major CS-containing wastewater stream, VI, AUTHORITY TO ISSUE CONSENT ORDER. 1. The WVDEP is the state agency vested with the authority to protect the environment in West Virginia, 2. Article 12, Chapter 22 of the West Virginia Code, the Groundwater Protection Act, grants to the WVDEP the authority to protect the State's groundwater from any contaminant groundwater is found, to institute a civil action or issue an order and, where contaminated requiring that groundwater be remediated. Article 5, Chapter 22 of the West Virginia Code. the Air Pollution Control Act. institute a 3. authority to protect the State's air from pollutants and to grants to the WVDEP the civil action or issue orders to enforce the statute. WVDHHR-BPH is the state agency vested with the authority to regulate and 4. The suppliesin West Virginia. protect drinking water Chapter 16 of the West Virginia Code, grants to the WVDHHR-BPH 5. Article 1, public drinking water supply of the state and to perform all the authority to protect the its purity and safety, and further grants to the WVDHHR-BPH itnhveeasutitghaotrioitny tnoecinesstsiaturytetoacatsiosnusreand issue orders to restore the purity of said water supply. VII. REQUIREMENTS OF CONSENT ORDER. The Agencies have concludpeodtetnhtaitalitriisskoof fgtrheeatpirmespeonrtcaenocefCto8 hinavtehesuefnfvicirieonntmdeantat iunpaonnd which tothdeeFtearcmiliitnieest.heThsceorepfeoaren,dthe Agencies require the following: around Establishment of Groundwater Investigation Steering Team. A. Investigation Steering Team" (GIST) shall be established with 1. A "Groundwater consisting of WVDEP, WVDHHR-BPH, EPA Region HI, and DuPont. members of the team will be the team leader. The objectives and specific tasks of the The WarVeDsEetPforretphreinsefnutlal tiinveAttachment A of this Consent Order. Hfouwlfeilvlienrg, tthhee pmraimjoarriytypoufrpthoese team of the GIST will be to oversee an expeditious, phased approach to performed with oversight from the rGeqISuTiresmhaelnl tbsesfeutnfdoertdh biny DSeucPtoionntsinA atchcroorudgahncCe. wTihthe Sweocrtkion Vin of this Consent Order. Upon conclusion of key milestones in the tasks set forth in Attachment A, the regarding GIST sh2a. ll issue interim or final reports settainndg pfolurtmh efiniddeinntgisficoaftifoanct aasnddecsocnricbleudsiionnsAttachment A shall survive the backAgnroyugnrdoudnadtaw, agtreorumnodnwiatoterrinmgopnliatnordinegve, loped pursuant to Attachmenptermit modification for A. termination of this Consent Order and shall be incorporated as a modification minor of the plans upon renewal of the the Facilities. DuPont reserves the right to request Facilities' permits. B. National Pollutant Discharge Elimination System Requirements. 1. Except as occasioned by no-flow conditions, DuPont shall pVeirrfgoirnmia/mNoantitohnlyal sampling for C8 at the Local Landfill at certain outfalls identified in West 0076538 as Outfalls 101 Pollutant Discharge Elimination System ("WV NPDES") Permit No. > 004 and 005. Except as occasioned by no-flow conditions, DuPont shall perform monthly 2. sampling for C8 at the Washington Works facility at certain outfalls identified in WV NPDES Permit No, WV0001279 as Outfalls 001,002,003, 005, 007, and 105. 3. Except as occasioned by no-flow conditions, DuPont shall perform monthly sampling for C8 at Dry Run Landfill at all outfalls identified in its WV NPDES Permit No. WV0076244. Except as occasioned by no-flow conditions, DuPont shall perform monthly 4. sampling for C8 at Letart Landfill at all outfalls identified in its WV NPDES Permit No. WV0076066. With respect to the requirements of paragraphs VILB.l through VII.B.4, all 5. sampling shall be performed pursuant to established EPA guidelines, where applicable, and results shall be delivered to the WVDEP within thirty days of receiving such results. DuPont shall record and report all attempts to sample under no-flow conditions. If 6. Within 90 days of the Effective Date of this Consent Order, DuPont agrees to obtain a sample from each surface' or alluvial water intake for public water supplies along the Ohio River in the area extending ten river miles downstream of the Washington Works facility. and one river mile upstream of the Washington Works facility. If concentrations of C8 above the Detection Limit are found in any sampled public water supply within the upstream or downstream segments initially sampled, the segments within which intakes are to be sampled shall be extended to twenty river miles downstream or two river miles upstream, as appropriate. concentrations above the Detection Limit are found in any segment so extended, additional sampling will be performed on water intakes within thirty river miles downstream or three river miles upstream, as appropriate. 7. The additional monitoring requirements contained m this subsection shall be incorporated into the Facilities' West Virginia/National Pollutant Discharge Elimination System permits by minor modification. DuPont reserves the right to request a modification of these requirements upon renewal of the permits, C. Toxicological and Human Health Assessment. 1. DuPont agrees to fund the various tasks set forth below as a part of this Consent Order by establishing an escrow account at a bank agreed to by the Parties, or by some other means agreed to by the Parties. Disbursements from said escrow shall be authorized by the C8 ToxicityTeam Leader and.DuPont representative jointly as described below. .2. A C8 Assessment ofToxicity Team ("CAT Team") shall be established with members of the team consisting of representatives of: WVDEP WVDHHR-BPH EPA Region HI NICS ATSDR DuPont 3- The WVDEP representative shall be the Team Leader. ^ 4. The individual team members, the tasks of the team, and the team objectives are set forth in full in Attachment C of this Consent Order. 5. Upon conclusion of all the tasks set forth in Attachment C, the CAT Team shall issue a final report setting forth findings of fact and conclusions as to what extent there may be health risks associated with C8 at the Facilities. D. Emission Modeling Assessment. 1. The following information shall be submitted to the Division of Air Quality ("DAQ") within 30 days of the Effective Date except where a different deadline is provided in this subsection: a. A complete and accurate list of building dimension parameters for all structures located within the Washington Works facility that have a significant impact on the dispersion ofC8 emissions. Significant impact for each structure on the site shall be determined based on the "area of building wake effects" as defined in the EPA User's Guide to the Building Profile Input Program (BPA-454/R-93-038 Revised Feb. 8,1995). b. A complete and accurate list ofDuPont's cuirent permitted allowable emission rates and connrmed actual C8 emission rates in pounds per year for the year 2000 for all sources located within the Washington Works facility. Each emission point shall be listed according to its stack I.D. and corresponding permit number. For each stack identified above as emitting C8 DuPont shall list all relevant stack parameters to be used in air dispersion modeling. c. shall be supplied: For each emission point (stack) emitting C8, the following information i. Phase of C8 (solid, vapor or aqueous solution) at stack conditions. ii. The particle characterization to be used for modeling including the particle size distribution (microns), the mass fraction ofC8 in each particle size category, and the particle density (g/cm3). iii. For particulate emissions, scavenging coefficients (hr/s-mm) for both liquid and frozen precipitation to be used for wet deposition modeling based upon the particle size distribution and the EPA's Industrial Source Complex, Version 3 Model Guidance (EPA-454/B-95-003b Sept. 1995) ("ISC Guidance"). DuPont may submit, within 30 days of the^ Bffecrive Date, information to support the use of the normalized $cavenging coefficient in the ::l- ISC Guidance (Figure 11 of ISC Guidance) for C8's scavenging coefficients. DAQ shall approve or disapprove with justification in writing, DuPont's submis$lon. Should DAQ disapprove, DuPont shall have the right, within seven days, to request a meeting with DAQ and USEPA to address the deficiencies set forth in DAQ's letter and to request reconsideration ofDAQ's decision. Following a meeting of the parties, DAQ shall issue a decision letter regarding C8's scavenging coefficients within seven days of the meeting. DAQ reserves the right to require measurement of C8's scavenging coefficients in its decision and DuPont reserves the right to assert a claim of confidentiality in the event such a measurement is made. iv. For gaseous emissions, scavenging coefficients (hr/s-mm) for both liquid and frozen precipitation to be used for wet deposition modeling will be provided as a function of droplet size using formulae in the open literature based on the physical properties of C8 and consistent with Section 1.4 of the ISC Guidance. DuPont may submit, within 30 days of the Effective Date, information to support the proposed scavenging coefficient for gaseous emissions including information on the percentage ofC8 emissions that would be in gaseous form. DAQ shall approve or disapprove with justification in writing, DuPont's submission. Should DAQ disapprove, DuPont shall have the right, within seven days, to request a meeting -with DAQ and USEPA to address the deficiencies set forth in DAQ's letter and to request reconsideration ofDAQ's decision. Following a meeting of the parties, DAQ shall issue a decision letter regarding C8's scavenging coefficients within seven days of the meeting. DAQ reserves the right to require measurement of C8's scavenging coefficients in its decision and DuPont reserves the right to assert a claim of confidentiality in the event such a measurement is made, d. To the extent that the phases exist, a solid, liquid and vapor phase (T-P) diagram for C8 with respect to pressure and temperature. The temperature and pressure ranges shall be representative of exhaust gas conditions before and after control equipment. Estimates of C8's critical properties shall be provided along with measured ranges of phase transition temperatures. In lieu of a binary phase (T>x-y) diagram representing the vapor-liquid equilibrium e. between water and C8, the solubility and Krafft Point ofC8 in aqueous solutions, measured pK. value for C8 dissociation in aqueous solutions, and measurements ofC8 concentrations or related acidsaonbdspeHrvsedrewprheesnentetasttievde ionfathheearadnsgpeascoebGseCrvaetdvadruioriunsg actual coopnecraetnitnrgatcioonnsd,ittieomnsp.erFatuurrtehse,rmore a discussion regarding the volatility ofC8 in aqueous solutions as a function ofpH will be provided. The information in this paragraph shall be submitted to the DAQ within 60 days of the Effective Date. Henry's law coefficient for C8 and a discussion of its dependence on pH. The coefficientf.shall be defined at various temperatures covering the range observed during actual operations. Any carbon adsorption data in the form of isotherms for C8 adsorption. g. DAQ will provide DuPont an opportunity to comment on modeling methodology and assumptions prior to finalizing the modeling results.- 2. Any expenses incurred as a result of accurately supplying the information requested above shall be covered by DuPont. Upon submission of the information required by this Subsection VELD, DAQ 3. data if the analytical methodology or quality control reserves the right to disapprove any procedures are deemed inappropriate. VIII. REIMBURSEMENT OF COSTS. DuPont agrees to establish an escrow account to fund Reimbursable Costs under 1. Expenditures from this account shall be made upon joint approval by a duly this Consent Order. designated representative of the WVDEP and of DuPont ("designated representatives"). Written notice of such designation shall be sent to the persons identified pursuant to Section XVI of this provided DuPont with Consent Order. Prior to the execution of this Consent Order, WVDBP has an estimate of Reimbursable Costs that WVDEP expects to incur under this Consent Order. Within 10 business days of the Effective Date, DuPont shall deposit in the escrow 2. fifty thousand dollars ($50,000). Each expenditure from the account funds in the amount of including invoices and receipts. escrow account must be supported by an itemized accounting, replenished with additional funds whenever the balance is less than Said escrow account shall be thousand dollars ($10,000), or as agreed to by the designated representatives. Any ten unexpended amount remaining in the escrow account at the conclusion of the work to be performed under this Consent Order shall be returned to DuPont. DuPont's obligation to pay Reimbursable Costs under this Consent Order shal 1 3. 10 not exceed two hundred and fifty thousand dollars ($250,000). Except as to Reimbursable Costs which are addressed separately in this section, all other costs incurred by DuPont in carrying out its obligations under Consent Order shall be the sole responsibility and obligation of DuPont. IX. QUALITY ASSURANCE/QUALITY CONTROL. All sampling and analyses performed-pursuant to this Consent Order shall conform to EPA guidance regarding quality assurance/quality control, data validation, and chain of custody procedures. The laboratory performing the analyses shall be approved by the Parties prior to sampling. X. C8 REDUCTION PROGRAM. 1. Notwithstanding current permitted emission levels, DuPont agrees to limit overall C8 emissions to the air to no more than actual calendar year 2000 levels on a calendar year basis and shall further provide to the WVDEP monthly emissions reports regarding C8. The reporting requirement contained herein shall be modified to quarterly reports upon the issuance of a Screening Level derived following the procedures set out in Attachment C. 2. DuPont agrees to reduce emissions to the air and discharges to the water ofC8 collectively by 50% from actual 1999 levels by December 31,2003. 3. DuPont shall operate and maintain the filter and carbon .bed treatment system at its Washington Works facility with the goal of achieving 90-95% C8 removal efficiency in its major CS-containing wastewater stream. 4. dates: DuPont shall conduct th6 following construction projects and abide by the specified a. DuPont shall install an improved scrubber filter to replace recovery device T6IZC on permit Rl 3-815D. Construction shall begin no later than February 28, 2002. Initial operation shall begin no later than the date of start up after the April shutdown, or June 28,2002, whichever is earlier. b. DuPont shall modify the stack for emission point T6IZCE so that the emission point elevation is 170 feet above grade. The stack diameter, velocity, and flow rate shall be sized to provide effective dispersion ofparticulate emissions according to 45 Code of State Rules, Series 20 (Good Engineering Practice as Applicable to Stack Heights). Construction shall begin no later than February 28,2002. Initial operation shall begin no later than the date of start up after the April shutdown, or June 28, 2002, whichever is earlier. At times when device T6IZC is not operating, permitted emissions from scrubber T6JFC -shall be emitted to emission point 11 If .. I j i:: 1=:: | | w'i { ; I : i." R; ; :-3 T6IZCE. 5. DuPont shall conduct a scrubber optimization and recovery improvement program that shall consist of a study of scrubber operation for device C2DWC2 on permit Rl 3-614A. The study shall be complete by the end of March 2002. Provided the results are encouraging, the company shall implement identified improvements for this device and similar improvements for units C2DTC2 on permit R13-614A, C2EHC2 on permit R13-1953, and C1FSC2 on proposed permit for R13-2365A. Implementation of the improvements for the latter devices will be complete no later than the end of November 2002. XI. COMPLIANCE WITH SCREENING LEVELS. 1. The following requirements shall apply only if the procedures set out in Attachment C have been followed: - a. No later than 60 days after receipt of notification from the Agencies that data or information developed pursuant to this Consent Order or other information that is recent and valid demonstrates that DuPont's operations have resulted in C8 exposures above the Screening Levels derived following the procedures set out in Attachment C> DuPont shall submit a plan for review and approval by the Agencies that is designed to reduce such exposures to levels below the Screening Levels within a reasonable time (the "Remedial Plan" or "the Plan"). b. Within 30 days of receipt of the Remedial Plan submitted by DuPont, the . "WVDEP shall, upon consultation with the WVDHHR-BPH and based upon accuracy, quality, and completeness, either approve or disapprove the Plan. If the WVDEP disapproves the Remedial Plan, the WVDEP shall notify DuPont in writing that the Remedial Plan has been disapproved and shall specify the reasons for such disapproval. DuPont shall resubmit the Remedial Plan as revised to address the deficiencies identified in the notice. DuPont's failure to submit an approvable Remedial Plan shall be deemed a violation of this Consent Order. 2. In the event EPA or the WVDEP develops and finalizes a reference dose/screening level for C8 in accordance with applicable'statutory and regulatory requirements ("the Regulatory BPA Standard") that would be applicable to Dupont*s activities or the Facilities independent of this Consent Order, DuPont's obligations under this Section shall be determined with reference to the Regulatory EPA Standard. DuPont reserves all rights it may have to comment upon, object to, or appeal the Regulatory EPA Standard in proceedings separate and apart from this Consent Order. ^ XII. COMPLETION OF CONSENT ORDER. 1. Except as to DuPont's obligations under Section XI, this Consent Order and GuPont's obligations hereunder shall terminate upon issuance of a completion letter(s) from the \ Secretary of the WVDEP or his designee and from the Commissioner of the WVDHHR-BPH to 12 DuPont. In a timely manner following receipt of a written request from DuPont the respective Agencies shall issue the completion letter(s) to DuPont or shall issue a letter to DuPont detailing the obligations and work that have not been completed in accordance with this Consent Order. The Parties agree that the Agencies' obligation to issue this letter shall be deemed a non-discretionary duty. 2. DuPont's obligation to achieve and maintain compliance with the Screening Levels as provided in Section XI of this Consent Order shall survive the termination of this Consent Order. Such obligation shall terminate only as provided in Section XI or upon agreement of the Parties. XIII. ADDITIONAL ACTIONS. The Agencies, individually or collectively, pursuant to their statutory duty and authority, may determine that additional action, beyond the tasks set forth in this Consent Order, is necessary to protect human health and/or the environment. Nothing in this Consent Order shall be construed as restraining or preventing the Agencies from taking such actions. Nothing in this Consent Order constitutes a satisfaction of or release from any claim or cause of action against DuPont for any liability it may have pursuant to the federal Clean Water Act, the federal Clean Air Act, the federal Safe Drinking Water Act, the West Virginia Groundwater Protection Act, the West Virginia Air Pollution Control Act, other statutes applicable to this matter, or West Virginia common law. Nothing in this Consent Order in anyway constitutes a modification or waiver of statutory requirements of DuPont and nothing in this Consent Order shall obligate DuPont to undertake any actions not specified herein. J XIV. ENFORCEMENT. Enforcement of this Consent Order may be had by the filing of a civil action by any of the Agencies in the Circuit Court of Wood County, West Virginia. Violation of the terms and conditions of this Consent Order by DuPont is a violation of the West Virginia Code and may result in enforcement action being taken, including a request for civil penalties as set forth by law. DuPont shall not be liable for violations of this Consent Order due to any "Force Majeure" condition. XV. CONTENTS OF CONSENT ORDER/MODIFICATION. The entirety of this Consent Order consists of the terms and conditions set forth herein and in any attachments or exhibits referenced herein. Modification of the terms and conditions of this Consent Order including any modification oftimeframes or deadlines established in this Consent Order shall be made only by agreement of the Parties in writing, except that modifications to any 13 requirement set out in the attachments to this Consent Order maybe made upon consensus of the members of the GIST or the CAT Team, as appropriate. XVI. ADDRESSES FOR ALL CORRESPONDENCE All documents, including reports, approvals, notifications, disapprovals, and other correspondence, to be submitted under this Consent Order shall be sent by certified mail, return receipt requested, hand delivery, overnight mail or by courier service to the following addresses or to such addresses DuPont or WVDEP may designate in writing. ^ Documents to be submitted to WVDEP should be sent to: ^.. WV Department of Environmental Protection 1356 Hansford Street Charleston, West Virginia 25301 . Attention: Annando Benincasa, Esq. Attention: Dee Ann Staats, Ph.D. Phone No.: (304) 558-2508 ^.. Documents to be submitted to WVDHHR-BPH should be sent to: WV Department of Health and Human Resources Bureau for Public Health 815 Quarrier Street, Suite 418 Charleston, West Virginia 25301 Attention: William Toomey, Manager of Source Wpter Assessment Program Phone No.: (304)558-2981 Documents to be submitted to DuPont should be sent to: E.'I. du Font de Nemours and Company Washington Works P.O. Box 1217 Parkersburg, West Virginia 26102 Attention: Paul Bossert Phone No.: (304)863.4305 and 14 E. I. du Pont de Nemours and Company Legal Department, Suite D-71 1007 Market Street Wilmington, Delaware 19898 Attention: Bernard J. Reilly, Esq. Phone No.: (302)774-5445 XVII. AUTHORIZED SIGNATORIES/NON-ADMISSION. The undersigned representatives state that they have had full and fair opportunityto review this ConsentthOisrdCeor nasnednht aOvredehradfreoeplpyoarntudnwitiythtofuallllokwnofworlethdegier ocofuitnssteelrtmosdaontdhecosnamdietions. authority to enter into this Consent and therTehfoereunednetresrigned do hereby confirm that they have the Order and have the authoritythtoisbCinodnstehnetirOrerdsepre,cntiovre epxaerctyu.tion thereof shall constitute an expressly all rights Neither the terms of admission by DuPont of any fact or of any legal liability. DuPont reserves and defenses that may be available in any proceeding involving third parties or involving "WVDEP and WVDHHR-BPH in any other matter. This Consent Order may be signed in counterparts and shall be effective upon signature of all the Parties below ("Effective Date"). Entered this /^-day of /W^/SQDQQ\. by: "WEST VIRGINIA DEPARTMENT OF ENVIRONMENTAL PROTECTION " BY: . WILLIAM.K'ADAMS, DEPUTYSECRETARY West Virginia Department of Environmental Protection 1356 Hansford Street Charleston/West Virginia 25301 Entered this A^dayof^^., 2001. by: 15 WEST VIRGINIA DIVISION OF HEALTH AND HUMAN RESOURCES - BUREAU FOR PUBLIC HEALTH B-V: TJRZnf/fi^M^y ^TAf.^yL^Uy< 'CUM-^M21-SSI/U/'NCT? Bureau for Public Health West Virginia Department of Health and Human Resources Diamond Building, Room 702 , 3 50. Capitol Street Charleston, West Virginia 25301 Entered this /S''dav of I ITV , 2001, by: - E. I. DU FONT DE NEMOURS AND COMPANY 16 Attachment A C8 GROUNDWATER INVESTIGATION STEERING TEAM A team of scientists shall be assembled to assess the presence and extent ofC8 Washington in drinking water, groundwater and surface water at and around the DuPont Works facility, and the Local, Letart, and Dry Run Landfills- The Groundwater scientists from WVDEP, WVDHHR- Investigation Steering Team (GIST) shall include shall fund the GIST via an escrow account BPH, EPA Region m, and DuPont. DuPont VIII of the attached Consent Order ("the Consent Order'*). as provided in Section shall be authorized jointly by the WVDEP GIST leader, Disbursements from this account and the DuPont representative, Andrew S-. Hartten. A schedule summarizing key GIST tasks, submittals, start and end dates is provided at the end of this document. GIST Member Orgamzations/Representatives/GeneFraulnctions WVDEP . David Watkins -Groundwater Protection- GIST team leader; escrow funds disbursement oversight; project management and coordination George Dasher-advisor and technical review Dee Ann Staats, Ph.D .-advisor EPA Region HI Garth Connor-science advisor Jack C. Hwang - Hydrogeologist Roger Rheinhart-Environmental Engineer DuPont Andrew Hartten-Principal Project Leader/Hydrogeologist-technicarleview, project management and coordination of field investigation activities; escrow funds disbursement oversight. WVDHHR-BPH William Toomey-Manager, Source Water Assessment Program- Bureau for Public Health advisor A-l GIST Team Objectives and Efforts The primary objective of the GIST is to efficiently review and direct groundwater and surface water monitoring and investigation activities as prescribed in the Consent Order and in this Attachment. The GIST will utilise a phased approach and employ rapid team decision making toward meeting the requirements in an efficient and timely manner. Unless otherwise directed by the GIST, the tasks outlined below shall be performed by DuPont or its representatives. The GIST will issue a final report(s) with findings and conclusions regarding groundwater quality in and around the Facilities, and the extent of groundwater contamination in and around the Facilities, The GIST final report shall further make recommendations regarding the need for any'further work or actions that need to be taken to assure protection of groundwater quality and human health into the future. The tasks set forth below and in the Consent Order are the minimum tasks to be performed by DuPont and the GIST pursuant to the Consent Order. Additional tasks may be necessary to assure the goals [full groundwater assessment and C8 impact, plume identification, and receptor identification] of the GIST and the Consent Order are met. Those tasks shall be agreed upon by the GIST. Key Tasks of GIST Task A: Groundwater Use and Well Survey/Groundwater Monitoring Objectives: Conduct a distance-phased groundwater well and water use survey within a 1-mile (and possibly 2 and 3-mile) radial distance or directionally focused distance of the Washington Works and Local, Letart, and Dry Run Landfills.' Summary: The phased approach to the water and groundwater well use survey will allow the GIST to focus efforts along established C8 impact transport pathways and cease activities in directions where impacts are not present or where there are minimal concentrations. Data results tables will be generated in a timely manner to allow the GIST to meet, evaluate the data, and determine the next course of action. The GIST will determine when the final groundwater well use survey shall be released, DuPont agrees to perform, under the supervision of the GIST and through an agreed-to third party, a groundwater use and well survey identifying and sampling all groundwater wells within a 1-mile radius of the three landfills set forth above and the Washington Works facility. The phased approach may be amended by the GIST should field conditions require, e.g., lack of sampling wells in the 1-mile radius, lack of quality sampling points within the 1-mile radius. Sampling shall be performed with the specific purpose of finding and measuring the C8 concentration in water. Should concentrations ofC8 found in groundwater wells exceed 1 pg/1 within the 1-mile radius, the GIST will determine 1 The water use survey should be in substantially the same format as Attachment B. A-2 whether to expand the well survey to a 2-mile radius, a 3-mile radius, or in a specific direction only. Drinking water wells that measure above 1 ug/1 shall be re-sampled at a frequency to be determined by the GIST. Note: The level of 1 ug/1 is utilized in this Consent Order for monitoring purposes only and not as a benchmark for determining risk and this level may be adjusted as determined the GIST in furtherance of the tasks and objectives set forth in this Attachment. * Timing: The initial well survey within a 1-mile radius of the Facilities will be conducted within 60 days of the Consent Order's Effective Date. Additional well survey activities will be conducted on a schedule to be determined by the GIST. Task B: Assessment ofExistiug.Groundwater and Surface Water Monitoring Data Objectives: Develop and implement a monitoring plan that determines the presence and extent ofC8 in drinking water, groundwater, and surface water in and around, the Washington Works facility and Local, Letart, and Dry Run Landfills and provide a compilation of all available groundwater/surface water monitoring and hydrogeologic characterization data for each facility, as reflected in Table A-l. * Summary: The GIST will be tasked with an expedited evaluation of existing historical data and hydrogeologic information in order to prioritize the initial scope of work for continuing groundwater monitoring and any additional investigation activities (e.g., monitoring well installations) required under plume identification. DuPont shall provide all historical data and hydrogeologic information it may have related to the Facilities. Timing: Within 30 days of the completion of Task A, the GIST will review all the C8 analytical and facility hydrogeologic information to determine the scope of work for groundwater monitoring and additional investigation. The GISTwill then establish a schedule for those activities. It is anticipated that a summary of all historical information for each facility will be submitted to GIST within 60 days of the Consent Order* s effective date. Task C: Plume Identification/Groundwater Assessment * Objective: Determine the vertical and horizontal extent of any and all C8 impacted groundwater exceeding 1 ug/1 or as directed by the GIST, which may determine a lower threshold than 1 ug/1. This task shall also include an assessment ofC8 impacted groundwater at Letart Landfill and its impact on the Ohio River and public water supplies along the river. * Summary: The GIST shall first review historical data and results of Task A to determine an appropriate scope of work. Activities should be prioritized to address groundwater plumes contributing to or with the potential to flow toward off-site receptors, with emphasis on those areas where groundwater is used as a drinking water source. A-3 Upon completion of investigation activities, DuPont shall provide the GIST with predicted groundwater flow and contaminant transport models to assess future plume migration. Timing: Upon review of all available information and on a schedule to be determined by the GIST, the GIST will complete an initial evaluation of data to determine and prioTrihtiezetipmluinmgeoifdtehnetiifnicitaiatilopnh. ase of peslutambelisihdeedntbifyictahteioGnI/SinTv.eFstuigrtahteior ninavcetsivtiigtiaetsoraynd shall oatchtievritaiecstivnietieedsewd iallndbeagorneea dstcohebdyutlhee GIST to carry out the goals of the GIST be performed by DuPont on a schedule established by the GIST. - ModelmR Any and all modeling performed pursuant to this attachment and the Consent Order approved by the shall use Groundwater Modeling System, or some other model as GIST. A-4 TABLE A-l : w>.^,-.^.-. ^^^^OMISlHMtHb^ 'Sit.W- i'f ',.f-.K^tA^a-',st..?>?B.->,.-t ' ..-. .'.'; j^" a. Dependent upon the availability of certain information, an ' '' ^;_____:__--------_------------------_--' ''- ^.'"'".^ ''' A location map. A site map showing the location of all known groundwater monitoring wells, residential groundwater wells and public historical data summary water supply within a 1-mile radius the Facilities. documented in a report that includes: Top'of-groundwater maps. These should span the entire sampling life of the site and should be no less than yearly. IfDuPont has only one year's worth of data for a given site, then these maps should be for each quarter; ifDuPont has several years worth of data for each site, then these maps can be annual. C8 concentration contour maps. These should span the entire sampling life of the site afad should be no less than yearly- IfDuPont has only one year's worth of data for a given site, then these maps should be for each quarter, if DuPont has several years worth of data for each site, then these maps can be annual. All the C8 groundwater data that has been collected to date. These data should be submitted m easy-to-read tables. These tables should use the method, "<x", to designate all concentrations below the laboratory's minimum detection limit (not "ND" or some other abbreviation), and they should use "mg/" or "|Ag/" as the unit designation. If unable to provide the above data, DuPont shall document the reasons why it is unable to gather and submit the information. b. A groundwater monitoring plan for the Facilities which should C8 sampling. The samples should be taken from all the wells at the three landfill sites and from a select number of wells at the Washington Works plant. These select wells . address, at a minimum: are to be chosen by the GIST before the groundwater monitoring program begins based on evaluation of historical data/information. The frequency of sampling shall be monthly for the first four months following the Effective Date and quarterly thereafter. Any new wells required for monitoring or plume identification purposes will be integrated in each site's groundwater monitoring program on a schedule agreed to by the GIST. A.5  Report of Results. Reporting should be quarterly and to the WVDEP Groundwater Program at the following address. WVDEP Division of Water Resources Groundwater Program 1201 Greenbrier Street Charleston, West Virginia 25311 Re: DuPont/CSmonitoring. Each report should include the following: (a) A site location map. (b) A site map showing the groundwater monitoring well locations. (c) A top-of-groundwater map. (d) A C8 concentration map. (e) Groundwater elevation and well screen data. (f) A table of all the historical C8 sampling data. .Note: where available information allows, abbreviations should not be used to designate No Detect concentrations and the units "ppb" and "ppm" should not be used. (g) Laboratory analysis sheets. (h) Chain of custody records. A-6 Attachment B GROUNDWATER WELL USE SURVEY Name: Address: ___ Phone: ___ Best Time to Contact Owner: No___ Do you have one or more water well(s) on this property? (It need not be in use currently.) If no, stop now and return survey. Yes County Water Well Permit No. 2. Is the well(s) currently (circle one) used unused or filled in? 3. Is the well(s) used for drinking water? Yes ___ No ___ 4. Is this well(s) used for other purposes? If yes, please specify uses below: 5. What is the approximate frequency of use? Circle One: Daily Weekly Monthly Summer 6- Date last used? -^ _ _____________ 7. Is there a pump in the well? Yes No ____ ___ ___ 8. Is there a conditioner, softener, chlorinator, filter, or other form of treatment for the system? Yes No If so, what is the form of treatment? B-l ___ ___ 9. Is there any faucet where water does not first pass through the treatment system? Yes No If yes, is it (circle one) inside or outside? 10. What year was the well constructed? 11. Please provide the following information regarding the well(s) if known: (circle one) A. Total Depth (feet below ground surface): 30-60 60-90 90-120 120 or more B. Casing Type: PVC steel stone none other C. Well Construction: dug drilled open or uncased bedrock D. Screened Interval (length in feet): 0-10 10-20 20-30 30-60 60 or more E. Well Diameter (inches): 0-6 6-12 12-24 24 or more L B-2 Attachment C C8 ASSESSMENT OF TOXICITY TEAM A team of scientists shall be assembled to assess the toxicity and risk to human health and the environment associated with exposure to ammonium perfluorooctanoate (C8) releases from DuPont's activities. The C8 Assessment of Toxicity Team (CAT Team) shall include scientists from academia, government, non-profit organizations, and industry. The CAT Team also shall include the WVDEP Environmental Advocate, Pam Nixon, as a representative of West Virginia* s citizens. The WVDEP, utilizing funds from an escrow account funded by DuPont,- shall .contract with a non-profit organization, the National Institute for Chemical Studies (NICS), for the services described herein. Point of contact for theNICS shall be Jan Taylor, Ph.D. The NICS shall subcontract with Marshall University's Center for Rural and Environmental Health for services in risk communication provided by James Becker, M.D. and his staff. Dr. Becker shall familiarize himself with the toxicity ofC8, the work performed by TERA as described herein, and attend public meetings to provide expertise in risk communication. The NICS shall subcontract with the non-profit scientific organization. Toxicology Excellence for Risk Assessment (TERA) whose point of contact is Joan Dollarhide, Ph.D. The TERA shall provide services in toxicology and risk assessment. Work assignments, tasks, and deliverables are described below. CAT Team Member Qrganjzatjons/ Re^resentativM WVDEP Fjinctjons Dee Ann Staats, Ph.D.' Science Advisor" team leader; escrow funds disbursement oversight; project management and coordination; toxicology/risk assessment and communication; Pam Nixon - Environmental Advocate - advisor; NICS Jan Taylor, Ph.D. -contractor administrative oversight; James Becker, M.D, (Marshall University) - consultant in risk communication; TERA (point of contact: Joan Dollarhide, Ph.D.)- consultant in toxicology/risk assessment: ' The parties may, in their discretion, elect to substitute their representatives with persons of similar qualifications. C-l DuPont Gerald Kennedy, Director of Applied Toxicology and Health, Haskell Laboratory " reviewer toxicology; escrow funds disbursement oversight; John Whysner, M.D. - toxicology/risk assessment and communications; Paul Bossert - Washington Works Plant Manager - communications; The following members of the CAT Team shall act as reviewers or advisors. WV Department of Health and Human Resources - Bureau for Public Health (WVDHHR-BPH) William Toomey - Manager, Source Water Assessment Program " advisor; Barbara Taylor - Director, Office of Environmental Health Services " advisor; Local representative - advisor; Environmental Protection Agency (EPA) Headquarters - Jennifer Seed - reviewer and advisor toxicology; Region III Philadelphia - Samuel Rotenberg, Ph.D. - reviewer and advisor toxicology/ risk assessment; Garth Connor- advisor hydrogeology; Roger Reinhart - reviewer and advisor Safe Drinking Water Act; Cincinnati - John Cicmanec, DVM - reviewer and advisor toxicology; Agency for Toxic Substances and Disease Registry (ATSDR) Atlanta - John Wheeler, Ph.D. - reviewer and advisor in toxicology/ risk assessment; Philadelphia - Lora Wemer - coordinator for ATSDR; Non-CAT Team Efforts Other efforts are currently underway which may produce information for the CAT Team to utilize. The CAT Team will coordinate and communicate closely with these other efforts. These include: 1. Dupont's air modeling ofC8 emissions from the Washington Works plant; 2. WVDEP's air modeling ofC8 emissions from the Washington Works plant; C-2 3. USEPA Draft Hazard Assessment which summarizes the available toxicity information regarding C8, to the extent completed prior to the assessment contemplated herein; 4. ATSDR's Health Consultation that. estimates the risk to the community associated with C8 in drinking water from the Lubeck Public Service District, to the extent completed prior to the assessment contemplated herein. 5. Existing C8 concentrations in Lubeck Public Service District data. 6. Groundwater C8 Analysis (see GIST activities described in Attachment A) and Well Use Survey (see example survey in Attachment B) at the residences in the area of the 3 landfills and the Washington Works Plant. Tasks of CAT Team The tasks to be performed by the CAT Team are described briefly in Table 1, and in more detail below. These tasks are discussed below within the context of a Scope of Work for both Dr. Becker and for TERA as well. Tasks of the CAT Team shall be organized into three phases. Phase I includes those tasks necessary to prepare for and hold the first public meeting. In Phase n, TERA shall conduct such scientific tasks as: reviewing available toxicity and epidemiological studies; developing Provisional Reference Doses and Screening Levels for protection of human health; evaluating existing information relative to ecological health; and conducting one general risk assessment involving comparisons of exposure concentrations to Screening Levels, for the three landfills and the Washington Works Plant, and the Lubeck Public Service District. TERA shall prepare a report on their findings. Phase III includes those tasks necessary to prepare for and hold the second public meeting. The results of the C8 groundwater analysis and risk assessment shall be presented in the second public meeting. No communication between Dupont representatives and NICS, Dr. Becker, or TERA shall be permitted without the participation of Dr. Staats. All information will be provided to Dr. Becker and TERA by WVDEP; thus, all information contributed to the effort by Dupont shall be sent in triplicate to Dr. Staats for forwarding to Dr. Becker and TERA. Phase I TASK A-l: First Public Meeting Two public meetings are anticipated for this project. The First Public Meeting shall occur in Phase I for the purposes of introducing the CAT Team and other involved parties to the public; relating historical information on previous concentrations ofC8 in Lubeck Public Service District water supply, informing the citizens of the ensuing activities; and inviting the public to participate by cooperating with sampling and survey efforts in the Groundwater C8 Analysis and Well Use Survey. In order to prepare for the C-3 First Public Meeting, CAT Team members shall familiarize themselves with the available lexicological information concerning C8. A CAT Team meeting shall be held Immediately prior to the first public meeting to: (1) conduct a site visit to the three landfills and the Washington Works Plant, and surrounding residential areas; (2) discuss the toxicity ofC8 and other pertinent data; (3) prepare an agenda for the public meeting; (4) coordinate and prepare for the public meeting. Finally, the First Public Meeting will be held and public questions and comments will be recorded by WVDEP. TABLE 1. TASKS OF CAT TEAM Task A; Public Meetings (two meetings are anticipated) Objective: to inform the local citizens of the following: (in Meeting #1) intent to perform a groundwater well use survey and analysis for C8; intent to develop Screening Levels; and to ask for their cooperation in conducting the water use survey; arid (in Meeting #2) results of survey, chemical analysis, and risk assessment. Note that an interim public meeting may be required should six months pass from the first public meeting and the CAT Team Final Report has not been issued. Primary Responsibility: Staats______________________________ Task B: Development of Provisional Reference Doses Objective: to develop Provisional References Doses for C8 for the inhalation and ingestion (and dermal, if possible) routes of exposure. PrimaryResponsibility: TERA Task C: Development of Screening Levels Based on Protection of Human Health Objective: to utilize the Provisional Reference Doses to develop human health risk-based Screening Levels for C8 in air, water, and soil. Note a determination of the potential carcinogenicity of C8 will be conducted as well. Primary Responsibility; Task D: Ecological Data RTeEviRewA_______________________________ Objective: to review available information to determine whether sufficient studies have been performed and data have been collected to develop screening criteria for ecological receptors. Primary TaskE: Responsibility: Draft Report andTFEinaRl RAe_po_rt____________________' ^ . Objective; to present and discuss the results of the above tasks. Primary Responsibility: TERA________________ Phase II Tasks B.C.D, an_d E Development ofProyigionalJR.eference Doses and Screening Levels, and Risk Assessment In Phase II, TERA shall conduct the lexicological and risk assessment activities. After having reviewed the lexicological information regarding C8 provided by WVDEP, TERA shall consult with lexicologists on the CAT Team, as coordinated by Dr. Staats, regarding its proposed approach for this project. Following such consultation, TERA C-4 shall develop Provisional Reference Doses for C8 for the oral, inhalation, and dermal (if possible) routes of exposure. Then TERA shall calculate Screening Levels for water, soil and air based on the risk factors they have estimated. TERA shall perform one general risk assessment involving comparison of exposure concentrations to Screening Levels for the three landfills and the Washington Works Plant, and the Lubeck Public Service District water supply, that focuses on current risk to human health, including workers and residents. This risk assessment shall include: (1) identification of reasonably anticipated land use, surface water and groundwater use; (2) identification of receptors; (3) identification of exposure pathways; (4) identification of exposure concentrations; and (5) comparison of exposure concentrations to appropriate Screening Levels. TERA shall utilize data obtained from the other efforts discussed above such as air modeling; groundwater C8 concentrations in residential and public wells; residential groundwater well use survey; the USEPA's Draft Hazard Assessment; and ATSDR's Health Consultation (if available). TERA also shall review available information to determine whether sufficient studies have been performed and data have been collected to develop screening criteria for protection of ecological health, particularly aquatic life. TERA shall prepare a draft and a final document that discusses the results of their efforts and summarizes the data utilized from other efforts. As the tasks of the CAT Team and other involved parties' progress, data gaps and research recommendations may become evident. These shall be included in TERA's report as suggestions for further research to elucidate the toxicity ofC8. Phase III Second Public Meetinp The purpose of the Second Public Meeting is to present to the citizenry the result$ of the efforts of the GIST and CAT Teams including C8 concentrations in groundwater from residential wells and public wells the screening levels and the general risk assessment. Air modeling results of the efforts ofWVDEP and Dupont will be discussed also. The WVDEP will address any further actions that may be necessary. C-5 SCOPE OF WORK FOR JAMES BECKER IVLD. Dr. Becker is a medical doctor specializing in environmental health at the Marshall University School of Medicine Center for Rural and Environmental Health. He will be assisting the WVDEP in his specialty area of risk communication at the two anticipated public meetings. The specific tasks assigned to Dr. Becker are described below. Phase I Task A-l: First Public Meeting Dr Becker will assist in preparation for the first public meeting, and attend, the meeting providing expertise in risk communication. He will familiarize himself with the available toxicological data, which will be provided to him by WVDEP, with particular emphasis on the epidemiological studies. Note that the toxicological data already has been summarized in the Draft Hazard Assessment prepared by USEPA. No literature search or document retrieval will be required. Specific subtasks required in Phase I to prepare .for the first public meeting are described below: Subtask 1 - Familiarization with lexicological data provided by WVDEP including but not limited to: a. 8 compact discs'of information provided to USEPA under TSCA by 3MCorp (note only a small portion of this information concerns C8); b. Draft Hazard Assessment document from USEPA; c. ACGIH Threshold Limit Value (TLV). d. Journal articles and other information provided by WVDEP. Subtask 2 - Attend a meeting prior to the first public meeting to: D a. conduct a site visit of the 3 landfills and the Washington Works Plant, and local residential areas; b. discuss and prepare an agenda; c. discuss the toxicology and risks associated with C8 with the other CAT Team members. Subtask 3 - Attend First Public Meeting Phase III Task A-2 Second Public Meeting Dr Becker will assist in preparation for the second public meeting, and attend the meeting providing expertise in risk communication. The following subtasks will be required: Subtask 1 - Familiarizationwith the toxicological and risk assessment report prepared by TERA; C-6 Subtask 2 a. Attend a meeting prior to the second public meeting to: discuss the toxicology and risks associated with C8 with the other CAT Team members; b. discuss and prepare an agenda. Subtask 3 - Attend Second Public Meeting Note that the second public meeting is assumed to be the final public meeting; however, expansion of the results of data collection may warrant additional public meetings and an Scope of Work. C-7 SCOPE OF WORK FOR TERA TERA (Toxicology Excellence for Risk Assessment) is a non-profit organization that applies sound lexicological data to the risk assessment process to find common ground between environmental, industry, and government groups. TERA will be providing services in toxicology and risk assessment. TERA scientists will be developing risk factors and screening criteria; and conducting one general risk assessment for the 3 landfills, Lubeck Public Service District water supply and the Washington Works Plant. The specific tasks assigned to TERA are described below. Phase II Tasks B, C, D, and E: Development of Provisional Reference Doses and Screening Levels, and General Assessment of Risk Subtask 1 - TERA staff will familiarize themselves with the lexicological data provided to by WVDBP. No literature search or document retrieval will be required. Toxicological data to be provided to TERA shall include but is not limited to the following: . a. 8 compact discs of information provided to USEPA under TSCA by 3M Corp (note only a small portion of this information concerns C8); b. USEPA Draft Hazard Assessment for C8; c. Journal articles and other information submitted to WVDEP by DuPont. Subtask 2 - TERA staff will: a. identify all possible critical toxicological studies suitable for developing Reference Doses for the oral, inhalation, and dermal (if possible) routes of exposure; b. outline methodology for developing said Reference Doses and for developing Screening Levels for air, water, and soil based on said Reference Doses corresponding to each critical study identified in subtask 2-a; c. convene a meeting at the TERA facility in Cincinnati, Ohio, to present their findings in subtask 2-a and 2-b, and consult with CAT Team toxicologists as coordinated by Dr. Staats; d. finalize Reference Doses and Screening Levels based on recommendations of the CAT Team toxicologists as coordinated by Dr. Staats. Subtask 3 - TERA shall conduct one general risk assessment for the three landfills and Washington Works Plant, and the Lubeck Public Service District water supply based on current risk to human health. This risk assessment shall include: a) identification of reasonably anticipated land use, surface water and groundwater uses; C-8 b) identification of receptors; c) identification of exposure pathways; d) identification of exposure concentrations; e) comparison of exposure concentrations to appropriate Screening Levels; TERA shall utilize the following data in the risk assessment process: a) air modeling data from DuPont; b) air modeling data from WVDEP; c) water use data from the Well Use Survey; d) groundwater data from the Groundwater Well Analysis of C8 for residential wells; e) drinking water data from Lubeck Public Service District wells; f) any available ATSDR Health Consultation that assesses potential health effects from exposure to C8 in public supply drinking water. Subtask 4 - TERA shall review the ecological data and determine whether there is sufficient information to support the development of a C8 Screening Level for protection of ecological health Subtask 5 - TERA shall compile and discuss the results of the above tasks into a comprehensive report (draft and final versions), which also refers to and provides a brief summary of the following: a) USEPA's Draft Hazard Assessment ofC8; b) DuPont's air modeling data; c) WVDEP's air modeling data; d) groundwater data from the Groundwater C8 Analysis and Well Use Survey of Local Residents, and Lubeck Public Service District; e) ATSDR Health Consultation that assesses potential health effects from exposure to C8 in public supply drinking water, if available. Additionally, TERA shall include in the report any insights or recommendations for future research gleaned during this process that would further elucidate the toxicity of C8. Also, TERA shall provide in the report of a summary discussion of the relevance the carcinogenicity of C8 in rats to humans. C-9 | of - 3 - Ife --_-- ~ BoE . LoD RNR . "A ji | | CUTE ee 31 Lal li] Ca 70 foo Tel | [os ETT | .I TS VE -- D || oo es# TE 2 aTwhn aSESIriOE CT NES | | ; | | |: NEA Co TON ene DANY, NV ya A SRST 3 a Tel ere -- sien, " v oh Ll aN _ frre " 5 o*aksJ .. ~r f 2 <i FYSi TOK A. Ko . 2. | a J wn OL ) = | Lemar Ps Corporate Remediation Group | ovport Yorn Werks LE EXHIBIT EE [1 INE Food i i CE sR ra . - Lo me5 ew n fR ig hid | |L e2rARTCLAH NGRIGE. RZ EXT mgcS0 : | | . STE 4 : Ng NG bei | | NEEL ERR id wo go e[n2mW f l ; F | liamPye e lopTg CEaLYTT R GaNrEdeT, W faeL ' pole a EEE LE 58 ITE en +: NOTE ee wd p& JU mA eT a TL ENwDo Nn R oi CET at NL bleSESsE s AEs Uo lrans, [TS | rom as h E i 5 7 etd aL A Yoox ee 8 o~oY NT est r . e Lr eee wT i aN AM | A & | Lemmon Ze? a & scaLe dy ou me el m. PREEEELT | rms xu? EEF LS STE | wi hm N BE e a NTRT: Cl | ; AT 1g, Tor : i 24 CoN f' A A LL a TRU |Re { h/48 S| g QL | : b 2 bi g/L! Lo NC | : K :3 | EXHIBIT 3 1 1 1 1